State v. Whitnum-Baker, 150 A.3d 1174

On April 24, 2014, Lisa Whitnum‑Baker entered the Stamford Courthouse Law Library and got into a loud argument with another patron.
A librarian summoned a state marshal, Patrick Valcourt, who instructed Whitnum‑Baker to stay away from the other patron; she was uncooperative.
Marshals attempted to escort her out; while being escorted she yelled, attempted to bite Valcourt’s arm, and was then handcuffed and detained in the courthouse detention area.
She was arrested by state police and originally charged with breach of the peace (§ 53a‑181); the state later filed a substitute information charging her with creating a public disturbance (§ 53a‑181a).
The case was tried to the court, which found her guilty of creating a public disturbance; she appealed pro se, arguing insufficiency of the evidence.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Whitnum‑Baker)	Held
Whether there was sufficient evidence to convict under § 53a‑181a	Evidence showed violent/threatening conduct — attempted bite — satisfying subdivision (1) for creating a public disturbance	Trial court should have credited her testimony; her version undermines the marshals’ account and defeats an essential element	Affirmed: viewing evidence in favor of the verdict, a rational factfinder could find she engaged in violent/threatening behavior (attempted bite) satisfying § 53a‑181a

State v. Serrano, 91 Conn. App. 227 (review of sufficiency standard and deference to factfinder credibility)
State v. Lo Sacco, 12 Conn. App. 481 (construction of "violent, tumultuous or threatening" language in § 53a‑181a; requires conduct involving or portending physical violence)
State v. Jagat, 111 Conn. App. 173 (credibility determinations by the factfinder are not revisited on appeal)