State v. Parris

Citations

• 352 Conn. 652

Syllabus

Convicted of murder and various firearm offenses in connection with the shooting death of the victim, the defendant appealed to this court. During an interview with the police, the defendant confessed to shooting the victim and discussed in detail his prior struggle with homelessness and certain issues that he had with his stepmother and the victim, who was his next- door neighbor. The defendant expressed his belief that his stepmother had been scheming to prevent him from holding a job, finding housing, and maintaining relationships, and that she and the victim had been conspiring against him. At trial, the defendant asserted the defense of extreme emotional disturbance with respect to the murder charge, which the jury rejected. On appeal to this court, the defendant claimed, inter alia, that multiple instances of impropriety during the prosecutors' closing and rebuttal arguments deprived him of his due process right to a fair trial. Held: The prosecutors committed impropriety during closing and rebuttal argu- ments by repeatedly misstating the law on the defendant's extreme emotional disturbance defense, and, because that impropriety deprived the defendant of his due process right to a fair trial, this court reversed the defendant's murder conviction and remanded the case for a new trial on that charge. With respect to the prosecutors' comments during closing and rebuttal arguments that the defendant's state of mind ''[did not] matter'' with respect to whether he actually believed the circumstances regarding his stepmother, the extreme emotional disturbance defense embraces a standard that is subjective as to the defendant's belief and that requires a jury, in determining the reasonableness of the explanation or excuse for the disturbance, to consider the circumstances as the defendant believed them to be. Consequently, the defendant's subjective state of mind was an important component to his extreme emotional disturbance defense, and any argument by the prosecut