State v. Norris

Citations

• 213 Conn. App. 253

Syllabus

Convicted under two informations of the crimes of risk of injury to a child, assault in the third degree, breach of the peace in the second degree and interfering with an officer, the defendant appealed to this court. The defendant's convictions stemmed from his involvement in a domestic violence incident with his girlfriend, which her minor child witnessed, and from his aggressive behavior with a police officer and hospital staff after he was brought to a hospital following the domestic violence incident. He claimed that the trial court improperly failed to conduct an adequate independent inquiry into his competency to stand trial and to order a competency hearing at the start of trial following a prior evaluation in which he had been found competent to stand trial. He also claimed that the court improperly granted the state's motion for joinder of the cases for trial because the conduct alleged in the domestic violence assault case was significantly more brutal and shocking than the conduct at the hospital alleged in the interfering with an officer case. Held: 1. The trial court did not abuse its discretion in denying the defendant's motion for a competency evaluation or in failing to conduct an indepen- dent inquiry into his competency, the defendant having failed to meet his burden that, at the time he moved for the competency evaluation, the court had before it specific factual allegations that, if true, would have constituted substantial evidence of mental impairment: the court, before ruling on the motion, engaged in extensive dialogue with the defendant, observed his demeanor, took notice of his general pattern of disruptive conduct, reviewed the competency report in the case file, and determined that the defendant was competent to stand trial and that his repeated disruptions and assertions that he did not understand were a delay tactic and specifically referenced the defendant's behavior when denying the motion; moreover, the court concluded that, on the b