STATE v. ADAM BENEDICT, SC 19549

Judicial District of Litchfield

 Criminal; Juror Disqualification; Whether Defendant Deprived of Fair Trial by Trial Court’s Refusal to Strike Prospective Juror Where Juror was a Police Officer Whose Supervisor was a Member of Same Department that Investigated Defendant's Criminal Case.  The defendant was convicted of sexual assault in the fourth degree.  He appealed, arguing that the trial court violated his constitutional right to a fair trial in  rejecting his claim that a prospective juror, J.J., be disqualified for cause on the ground that J.J. had a connection to the state police, the law enforcement agency that investigated his case and arrested him.  The Appellate Court (158 Conn. App. 599) affirmed the conviction, concluding that the trial court did not abuse its discretion in denying the challenge for cause.  The court noted that the defendant had raised a common-law principal challenge to J.J., which would result in J.J.'s automatic disqualification if the defendant could establish that there was an "inextricably close relationship" between J.J. and the state police.  It determined that, while an inextricably close relationship exists where there is a master-servant relationship, the defendant failed to establish that there was such a relationship between J.J. and the state police.  The Appellate Court noted that (1) J.J. stated that he worked as a police officer in Southbury and that he worked under the state police because his supervisor was a state police sergeant, (2) J.J. stated that he did not know any of the state troopers who would be testifying for the state and that he would not afford the testimony of members of law enforcement agencies any greater credence than that of other witnesses, (3) the defendant did not challenge the prosecutor's statements that J.J. was employed by the town of Southbury rather than by the state police and that J.J.'s supervisor was not assigned to the same troop as the state police witnesses in this case, and (4) the defendant never asked J.J. about the scope, nature, or level of supervision he received from his state police supervisor in Southbury or about details regarding his relationship with the state police.  The court found that, given the sparse details regarding the nature of the relationship between the state police and the officers of the Southbury Police Department, the trial court did not abuse its discretion in finding no master-servant relationship here and in denying the defendant’s principal challenge to J.J.  The defendant appeals, and the Supreme Court will decide whether the Appellate Court properly concluded that the trial court did not deprive the defendant of a fair trial in denying his for cause challenge to juror J.J.