State v. McFarland

Citations

• 353 Conn. 169

Syllabus

Convicted of two counts of murder, the defendant appealed to this court. Although the murders occurred in 1987, the case remained unresolved until scientific advancements in DNA testing led to new findings that resulted in the defendant's arrest in 2019. In a pretrial motion to dismiss the murder charges, which the trial court denied, the defendant claimed that the thirty- two year delay between the murders and his arrest violated his rights under the due process clauses of the federal and state constitutions. On appeal, the defendant renewed his constitutional claims and also challenged the trial court's decision not to order a new competency hearing as well as an evidentiary ruling. Held: 170 SEPTEMBER, 2025 353 Conn. 169 State v. McFarland The trial court properly rejected the defendant's federal and state due pro- cess claims arising from the prearrest delay, as the defendant failed to establish that his conviction offended the community's sense of fair play and decency. With respect to its rejection of the defendant's claim under the federal constitution, this court unanimously adhered to existing precedent applying a two-pronged test to prearrest delay claims pursuant to which a defendant, to establish a due process violation, must demonstrate that actual and substantial prejudice resulted from the delay and that the state delayed the defendant's arrest to obtain an unfair tactical advantage or for other improper purposes. With respect to this court's rejection of the defendant's claim under the state constitution, a majority of this court adopted a balancing test similar to that endorsed by the trial court, pursuant to which the defendant must make a threshold showing of actual and substantial prejudice, the state then must establish the reasons for the delay, and, finally, the trial court balances the prejudice to the defendant against the state's reasons for the delay. The trial court did not abuse its discretion when it declined to order a new competency e