State v. Haynes

Citations

• 352 Conn. 236

Syllabus

Convicted of murder in connection with the stabbing death of the victim, the defendant appealed to this court. The trial court had precluded the state from using, in its case-in-chief, a statement given by the defendant to the police on the ground that, although the defendant had given the statement voluntarily, it had been obtained in violation of his right to counsel under Miranda v. Arizona (384 U.S. 436) and Edwards v. Arizona (451 U.S. 477). The court nevertheless permitted the state to use the statement to impeach the defendant's trial testimony in accordance with State v. Reid (193 Conn. 646), in which this court, relying on the United States Supreme Court's decision in Harris v. New York (401 U.S. 222), held that the Connecticut constitution permits the state to impeach a criminal defendant's trial testi- mony with a voluntary statement that was obtained in violation of Miranda. On appeal, the defendant claimed, inter alia, that this court should overrule Reid and conclude that article first, § 8, of the Connecticut constitution precluded the state from using his statement to impeach his trial testi- mony. Held: Guided by the relevant factors set forth in State v. Geisler (222 Conn. 672) for construing the Connecticut constitution, as well as stare decisis considerations, this court declined the defendant's request to overrule Reid and concluded that the state's use of the defendant's statement for impeach- ment purposes did not violate the state constitution. The defendant did not provide inescapable reasons that would compel this court to overrule Reid, insofar as the overwhelming weight of authority from other states aligned with Connecticut's existing view of the Harris impeachment exception, the defendant failed to establish that the rights of criminal defendants are not adequately protected by the policy articulated in Harris and Reid, which balances the valuable aid that the impeachment process affords the jury in assessing a defendant's credibility w