224 Conn.App. 652
Conn. App. Ct.2024Background
- Miguel Vega was convicted of serious felonies—including murder and home invasion—after a 2010 shooting, based on eyewitness testimony from people who knew him.
- At trial, multiple eyewitnesses identified Vega as the shooter, and prior altercations between Vega and the victims had occurred earlier that night.
- A key eyewitness, Alice Phillips, identified Vega during a 911 call and at trial. Other witnesses testified they heard Vega’s name shouted during the incident.
- Vega brought a habeas petition claiming Brady and ineffective assistance violations, partly based on Phillips testifying falsely in another (unrelated) 2009 case, which, Vega argued, should have been disclosed as impeachment material.
- The habeas court denied his petition and denied certification to appeal. Vega appealed this denial, challenging both the Brady and ineffective assistance rulings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Denial of certification to appeal | Court abused discretion by denying certification | No debatable or meritorious issues | No abuse of discretion; appeal dismissed |
| Suppression of exculpatory evidence (Brady) | State failed to disclose Phillips's prior false testimony | No duty to review unrelated file; no actual knowledge | No Brady violation; no duty to search unrelated files |
| Ineffective assistance: no eyewitness expert | Counsel should have consulted/called ID expert | Strategic choice; familiarity lessens ID issues | No deficiency; strategic decision reasonable, no prejudice shown |
| Ineffective assistance: failure to impeach | Counsel should've impeached Phillips with prior testimony | No nondisclosure proven; no evidence of prejudice | No ineffective assistance; no evidence of nondisclosure or harm |
Key Cases Cited
- Brady v. Maryland, 373 U.S. 83 (1963) (prosecution must disclose material exculpatory evidence)
- Strickland v. Washington, 466 U.S. 668 (1984) (standard for ineffective assistance of counsel)
- State v. Guerrera, 331 Conn. 628 (2019) (prosecutors not required to search unrelated files for exculpatory material)