State v. Meehan

Summary

The Connecticut Supreme Court reviewed James Meehan’s convictions for narcotics possession, larceny, and perjury arising from his testimony before a grand jury investigating police misconduct. The court concluded that the evidence was insufficient to support one perjury conviction and that evidence of alleged prior misconduct was improperly admitted to prove larcenous intent. The court affirmed the remaining convictions and declined to reach an unpreserved challenge to the admission of grand jury testimony under State v. Whelan.

Holdings

1. The evidence was sufficient to permit the jury to find beyond a reasonable doubt that Meehan possessed cocaine on three separate and distinct occasions between January 1 and April 30, 1994.
2. The evidence was sufficient to sustain the convictions for perjury based on Meehan's false grand jury statements that he had never used or possessed cocaine or arranged for cocaine to be purchased for him.
3. The conviction for perjury based on Meehan's alleged false testimony that he had not stolen money from Villarmarin could not stand; the judgment was reversed as to that count with direction to render judgment of acquittal.
4. The court declined to reach the merits of Meehan's claim that Lozada's memory loss was genuine rather than feigned and therefore did not satisfy Whelan's requirements, because the claim was not preserved in the trial court.
5. The trial court improperly admitted testimony that Meehan allegedly had stolen money from Befi during an earlier patdown search to prove Meehan's specific intent to appropriate Villarmarin's money.
6. The improper admission of Befi's testimony was harmful and required reversal of the larceny conviction and a new trial on that count.

Questions Presented

1. Whether the evidence was sufficient to sustain three convictions for possession of a narcotic substance.
2. Whether the evidence was sufficient to sustain three convictions for perjury based on Meehan's grand jury testimony.
3. Whether the trial court properly admitted Lozada's grand jury testimony as a prior inconsistent statement under State v. Whelan.
4. Whether the trial court properly admitted evidence of Meehan's alleged prior uncharged misconduct to prove intent to commit second-degree larceny.
5. Whether the improper admission of the prior-misconduct evidence was harmless.

Disposition

reversed_and_remanded