State v. Valle

Summary

The Connecticut Appellate Court affirmed David Valle’s convictions for two counts of cruelty to animals, threatening in the second degree, and interfering with an officer. The court declined to review the defendant’s unpreserved claim that exhibits relating to dismissed charges were improperly submitted to the jury because he did not identify the exhibits or articulate a legal or factual basis for exclusion. The court also rejected his as-applied vagueness challenge to General Statutes § 53-247 (a), concluding that his alleged conduct fell within the statute’s unmistakable core.

Holdings

1. The court declined to review the defendant's claim because it was not adequately preserved. A general objection to submitting all full exhibits did not identify the specific exhibits to be excluded or state the factual or legal basis for exclusion.
2. Section 53-247 (a) was not unconstitutionally vague as applied to the defendant because confining dogs in a dirty, unsanitary outdoor cage and failing to provide sufficient food or water for weeks or months falls within the statute's unmistakable core of prohibited conduct.

Questions Presented

1. Whether the trial court erred by submitting to the jury exhibits that related in part to charges on which the defendant had been acquitted.
2. Whether General Statutes § 53-247 (a) was unconstitutionally vague as applied to the defendant's conduct.

Disposition

affirmed