State v. Winfrey, 24 A.3d 1218

On Sept. 18, 2007, narcotics officers stopped the defendant after observing license plate and seat belt issues and parking in a lot.
A Terry pat-down led to the discovery of a white package with five wax folds believed to be heroin when the defendant manipulated his clothing.
The officers arrested him for interfering and, during the arrest, searched the defendant’s car, finding two bags of crack and three bags of marijuana in the center console.
The defendant swallowed the package of heroin; hospital testing and later testing showed cocaine and opiates in his system.
The defendant was charged with possession of narcotics with intent to sell, possession of a controlled substance, interfering with an officer, and tampering with physical evidence; he was convicted on the lesser offense of narcotics possession and on the other charged offenses.
The trial court sentenced him to seven years, plus five years of special parole.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the warrantless car search was permissible	State argues the search fell within the automobile exception.	Winfrey contends Miller/Connecticut limits warrantless car searches; Gant concerns apply and retroactivity is questionable.	Automobile exception valid; court need not decide Gant retroactivity because search was permissible.
Sufficiency of evidence for possessory offenses	State asserts constructive possession supported by driving the car, owner’s identity, and incriminating circumstances.	Winfrey contends nonexclusive possession doctrine insufficient to prove knowledge and control.	Evidence sufficient for constructive possession; jury could find dominion and control.
Admission of unredacted medical records	Records, including admissions and lab results, are probative and admissible under §§ 4-5(b) and 8-3(1)(5).	Records contain prejudicial prior misconduct; should have been redacted to protect from prejudice.	Admission not an abuse of discretion; any officer statements redaction was not error, and any error was harmless.
Jury instruction on reasonable doubt	Court’s reasonable doubt instruction aligns with prior Connecticut precedent and properly communicates standard.	Instructions dilute state burden of proof.	Instructions were proper and not reversible error.

Carroll v. United States, 267 U.S. 132 (U.S. 1925) (established automobile exception to warrantless searches based on probable cause)
State v. Trine, 236 Conn. 216 (1996) ( outlines warrantless search standards for vehicles)
State v. Miller, 227 Conn. 363 (1993) (limits warrantless searches of impounded vehicles under state constitution)
State v. Smith, 257 Conn. 216 (2001) (clarifies Miller limits and allows vehicle searches in public venues)
State v. Badgett, 200 Conn. 412 (1986) (vehicle searches and probable cause considerations under state law)
State v. Sanchez, 75 Conn. App. 223 (2003) (factors linking defendant to contraband in vehicle)