State v. Young
166 A.3d 704
Conn. App. Ct.2017Background
- Defendant Patrick Young was convicted by a jury of first‑degree assault (intentionally causing serious physical injury by means of a deadly weapon) and carrying a pistol without a permit; his probation was revoked.
- Victim (Turner), defendant’s cousin (Turner) and roommate (McFadden), and defendant’s girlfriend (Zambrano) were involved after Zambrano stole a $6,500 check; disagreement about cashing/keeping the money led to a confrontation.
- During a stop near woods, defendant retrieved a silver .38 revolver, forced Turner from the car, pointed the gun at her head, and later shot her multiple times (one bullet exited wrist, another hit torso; a .38 bullet was later removed).
- Zambrano led police to a marina where the recovered firearm matched the description (.38 Smith & Wesson).
- At trial defendant testified; the state impeached his credibility by introducing the names of three prior felony convictions (conspiracy to commit larceny, attempt to commit robbery, conspiracy to commit robbery).
- Defendant appealed claiming insufficient evidence, improper admission (and naming) of prior felony convictions, and that a supplemental jury instruction naming those convictions unduly highlighted them.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence for 1st‑degree assault | State: evidence (victim testimony, recovered gun, .38 bullet removed) permits inference of intent and serious injury | Young: witness inconsistencies and conflicting statements make evidence insufficient | Affirmed—evidence sufficient; credibility and inconsistencies are for jury to resolve |
| Admission of names of prior felony convictions for impeachment | State: prior larceny/robbery convictions are probative of veracity and admissible under impeachment rules | Young: naming felonies was unfairly prejudicial and suggested propensity to commit charged crimes | Affirmed—trial court did not abuse discretion; crimes bore on credibility and weren't so similar to charged offenses to make names unduly prejudicial |
| Supplemental jury charge naming prior convictions after deliberations began | State: supplement was to clarify limited use of prior convictions for credibility | Young: supplemental charge unduly highlighted convictions and marshaled evidence, prejudicing him | Affirmed—supplement properly limited jury use to credibility and protected defendant from improper use; naming convictions did not constitute impermissible marshaling |
Key Cases Cited
- State v. Revels, 313 Conn. 762 (2014) (standard for appellate sufficiency review)
- State v. Papandrea, 120 Conn. App. 224 (2010) (intent may be inferred from conduct and natural consequences)
- State v. Crumpton, 202 Conn. 224 (1987) (admissibility and naming of prior convictions for impeachment)
- State v. Geyer, 194 Conn. 1 (1984) (larceny/robbery convictions reflect on credibility; probative value vs. prejudice)
- State v. Muhammad, 91 Conn. App. 392 (2005) (test for undue prejudice: whether evidence will improperly arouse juror emotion)
