State of Connecticut v. Darius Armadore

Summary

The Connecticut Supreme Court affirmed the defendant’s murder conviction. It held that although the Appellate Court should generally permit supplemental briefing to raise an unpreserved claim based on the newly announced constitutional rule in Carpenter v. United States, denial of the motion was harmless because the Carpenter claim failed under the fourth prong of State v. Golding. The court also held that testimony about a phone call reporting the shooting was admissible as nonhearsay to show its effect on the hearer, and that any error would have been harmless.

Holdings

1. When a party seeks to raise an unpreserved claim based on a newly announced constitutional rule that arose while the appeal was pending, appellate courts should generally grant permission to file a supplemental brief, except in the clearest circumstances in which the claim would fail under one of the Golding prongs. The Appellate Court therefore abused its discretion by summarily denying the defendant's motion.
2. Assuming the defendant's unpreserved Carpenter claim was reviewable and that a constitutional violation occurred, the state proved beyond a reasonable doubt that admission of the defendant's historical CSLI was harmless.
3. A defendant generally lacks standing to challenge the admission of historical CSLI associated with a codefendant's phones because Fourth Amendment rights are personal and the defendant had no demonstrated reasonable expectation of privacy in those phones or records.
4. The defendant functionally preserved his hearsay claim even though counsel stated only 'Objection,' because the prosecutor's response and the trial court's ruling demonstrated that both understood the objection to be based on hearsay.
5. The testimony that a caller told Guilbert that the victim had been shot was properly admitted as nonhearsay because it was offered to show the statement's effect on Guilbert and to explain his subsequent actions, which helped establish the timeline.
6. Even if the phone-call testimony constituted inadmissible hearsay, its admission was harmless because the remaining testimony and other evidence allowed the jury to infer the relevant timeline and independently established the defendant's guilt.

Questions Presented

1. Whether the Appellate Court abused its discretion by denying the defendant permission to file a supplemental brief raising an unpreserved Carpenter claim after Carpenter was decided during the appeal.
2. Whether the defendant could challenge the admission of historical CSLI associated with his codefendant's phones for purposes of the harmless-error analysis.
3. Whether the defendant adequately preserved his hearsay objection to testimony about a phone call informing a witness that the victim had been shot.
4. Whether the phone-call testimony was inadmissible hearsay or was properly admitted to show its effect on the hearer.
5. If the phone-call testimony was erroneously admitted, whether the error was harmless.

Disposition

affirmed