State v. Ouellette, 271 Conn. 740

Summary

The Connecticut Supreme Court affirmed Michael Ouellette’s murder conviction after a three-judge trial. The court rejected challenges to his waiver of a jury trial and probable cause hearing, his plea of not guilty by reason of mental disease or defect, and the denial of a presentence psychiatric examination. The court held that the waivers were knowing and voluntary and that the asserted canvassing deficiencies did not warrant relief.

Holdings

1. A defendant who has been found competent to stand trial is competent to waive the right to a jury trial, and the defendant's waiver was knowing, voluntary, and intelligent under the totality of the circumstances.
2. The defendant's waiver of the probable cause hearing was knowing and voluntary and satisfied the constitutional and statutory requirements.
3. Due process did not require a canvass of the defendant concerning his assertion of not guilty by reason of mental disease or defect because the state vigorously contested the defense and the proceeding was adversarial.
4. The trial court did not abuse its discretion by denying the defendant's request for a presentence psychiatric examination under General Statutes § 17a-566.

Questions Presented

1. Whether the defendant knowingly, voluntarily, and intelligently waived his federal and state constitutional rights to a jury trial.
2. Whether the defendant knowingly and voluntarily waived his constitutional right to a probable cause hearing.
3. Whether due process required the trial court to canvass the defendant concerning his assertion of not guilty by reason of mental disease or defect.
4. Whether the trial court abused its discretion by denying the defendant's motion for a presentence psychiatric examination under General Statutes § 17a-566.

Disposition

affirmed