State of Connecticut v. Steven Gary, 273 Conn. 393

Summary

The Connecticut Supreme Court affirmed Steven Gary's convictions for murder, carrying a pistol without a permit, and criminal possession of a firearm. The court held that sufficient evidence supported the jury's finding of intent to kill under a transferred-intent theory and rejected claims concerning a post-verdict juror's doubts, denial of a mistrial, and refusal to conduct an evidentiary hearing into alleged juror misconduct.

Holdings

1. The evidence was sufficient to permit the jury to find beyond a reasonable doubt that the defendant intended to kill Sanders and, acting with that intent, killed Gilliard. Intent could reasonably be inferred from the altercation, the defendant's motive, his use of a loaded pistol, the manner in which he fired it, the wound inflicted, and the surrounding circumstances.
2. The trial court properly denied the motion for a mistrial because the juror's letter showed that he had voluntarily abandoned his doubts before voting for the verdict and did not establish that the verdict was nonunanimous or that the juror had been improperly coerced.
3. The trial court properly denied the requested evidentiary hearing because the juror's letter concerned the jurors' mental operations, doubts, interpretation of the evidence, and deliberative influence, rather than extraneous misconduct subject to judicial inquiry.

Questions Presented

1. Whether the evidence was sufficient for the jury to find beyond a reasonable doubt that the defendant had the specific intent to kill Sanders under a transferred-intent theory.
2. Whether the trial court improperly denied the defendant's motion for a mistrial based on a juror's postverdict letter expressing doubts about intent and alternative explanations for the shooting.
3. Whether the trial court was required to conduct an evidentiary hearing to investigate alleged juror misconduct based on the juror's descriptions of deliberations and possible misunderstanding of the law.

Disposition

affirmed