unified defense (Connecticut) · Go Syfert
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unified defense in Connecticut

13 Connecticut opinions name it 3 courts 1991–2025 2 in the last five years

The cases below were cited by Connecticut courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (4)

CaseFollowedCited
State v. Huffordgreen
conn · 1987 · cited in 2 Connecticut opinions naming this issue, 2023–2025
2 sentences

2025Compare State v. Hufford, 205 Conn. 386, 397 , 533 A.2d 866 (1987) (there was no prejudice when defense was simple denial that incident had ever occurred, and defendant did not assert that he would have changed his defense if information had charged him with each alternative in separate counts or in con- junctive), with Jackson v. State, 342 P.3d 1254, 1256 , 1258–59 (Alaska App. 2014) (prejudice existed because defense clearly differentiated between vaginal and anal penetration, asserting that one was consensual and one was accidental), and State v. Trujillo, 296 Kan. 625, 630 , 294 P.3d 281

2025Compare State v. Hufford, 205 Conn. 386, 397 , 533 A.2d 866 (1987) (there was no prejudice when defense was simple denial that incident had ever occurred, and defendant did not assert that he would have changed his defense if information had charged him with each alternative in separate counts or in con- junctive), with Jackson v. State, 342 P.3d 1254, 1256 , 1258–59 (Alaska App. 2014) (prejudice existed because defense clearly differentiated between vaginal and anal penetration, asserting that one was consensual and one was accidental), and State v. Trujillo, 296 Kan. 625, 630 , 294 P.3d 281

22
State v. Trujillogreen
kan · 2013 · cited in 2 Connecticut opinions naming this issue, 2023–2025
2 sentences

2025Compare State v. Hufford, 205 Conn. 386, 397 , 533 A.2d 866 (1987) (there was no prejudice when defense was simple denial that incident had ever occurred, and defendant did not assert that he would have changed his defense if information had charged him with each alternative in separate counts or in con- junctive), with Jackson v. State, 342 P.3d 1254, 1256 , 1258–59 (Alaska App. 2014) (prejudice existed because defense clearly differentiated between vaginal and anal penetration, asserting that one was consensual and one was accidental), and State v. Trujillo, 296 Kan. 625, 630 , 294 P.3d 281

2025Compare State v. Hufford, 205 Conn. 386, 397 , 533 A.2d 866 (1987) (there was no prejudice when defense was simple denial that incident had ever occurred, and defendant did not assert that he would have changed his defense if information had charged him with each alternative in separate counts or in con- junctive), with Jackson v. State, 342 P.3d 1254, 1256 , 1258–59 (Alaska App. 2014) (prejudice existed because defense clearly differentiated between vaginal and anal penetration, asserting that one was consensual and one was accidental), and State v. Trujillo, 296 Kan. 625, 630 , 294 P.3d 281

22
Jackson v. Stategreen
alaskactapp · 2014 · cited in 2 Connecticut opinions naming this issue, 2023–2025
2 sentences

2025Compare State v. Hufford, 205 Conn. 386, 397 , 533 A.2d 866 (1987) (there was no prejudice when defense was simple denial that incident had ever occurred, and defendant did not assert that he would have changed his defense if information had charged him with each alternative in separate counts or in con- junctive), with Jackson v. State, 342 P.3d 1254, 1256 , 1258–59 (Alaska App. 2014) (prejudice existed because defense clearly differentiated between vaginal and anal penetration, asserting that one was consensual and one was accidental), and State v. Trujillo, 296 Kan. 625, 630 , 294 P.3d 281

2023Compare State v. Hufford, 205 Conn. 386, 397 , 533 A.2d 866 (1987) (there was no prejudice when defense was simple denial that incident had ever occurred, and defendant did not assert that he would have changed his defense if infor- mation had charged him with each alternative in sepa- rate counts or in conjunctive), with Jackson v. State, 342 P.3d 1254, 1256 , 1258–59 (Alaska App. 2014) (prejudice existed because defense clearly differentiated between vaginal and anal penetration, asserting that one was consensual and one was accidental), and State v. Truji- llo, 296 Kan. 625, 630 , 294 P.3d

22
State v. Moyergreen
kan · 2015 · cited in 1 Connecticut opinions naming this issue, 2025–2025
2 sentences

2025See, e.g., State v. Moyer, 306 Kan. 342 , 358–63, 410 P.3d 71 (2017) (any error in court’s failure to instruct jury that it had to be unanimous as to specific act of fellatio that constituted criminal sodomy was harmless given that defendant asserted general denial to all of alleged sexual acts); State v. Voyles, 284 Kan. 239, 253 , 160 P.3d 794 (2007) (‘‘Kansas appellate courts have held a ‘failure to instruct’ in multiple acts cases to be reversible error except when the defen- dant presents a unified defense, e.g., a general denial.

2025See, e.g., State v. Moyer, 306 Kan. 342 , 358–63, 410 P.3d 71 (2017) (any error in court’s failure to instruct jury that it had to be unanimous as to specific act of fellatio that constituted criminal sodomy was harmless given that defendant asserted general denial to all of alleged sexual acts); State v. Voyles, 284 Kan. 239, 253 , 160 P.3d 794 (2007) (‘‘Kansas appellate courts have held a ‘failure to instruct’ in multiple acts cases to be reversible error except when the defen- dant presents a unified defense, e.g., a general denial.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Connecticut. Read the followed side critically anyway.

Also cited on this issue (5)

CaseCitedYears
In re Juvenile Appeal (84-AB) green
conn · 1984
2 sentences

1993In re Juvenile Appeal (84-AB), 192 Conn. 254 , 259 (1984).

1992In re Juvenile Appeal (84-AB), 192 Conn. 254 , 259 (1984).

111991–1993
Gillispie v. State green
moctapp · 2013
1 sentence

2025Stated in the language of the clearly erroneous standard of review applicable when no unanimity instruction has been requested, cases not containing a unified defense are reversed because the reviewing court is firmly convinced that there is a real possibility the jury would have returned a different verdict if the instruction had been given.’’); State v. Escobar, 523 S.W.3d 545 , 552–53 (Mo. App. 2017) (when defendant denied allegations of sexual abuse as whole, argued that victim fabricated story and presented no incident-specific evidence to contest either of two specifically described inst

12025–2025
State v. Voyles green
kan · 2007
2 sentences

2025See, e.g., State v. Moyer, 306 Kan. 342 , 358–63, 410 P.3d 71 (2017) (any error in court’s failure to instruct jury that it had to be unanimous as to specific act of fellatio that constituted criminal sodomy was harmless given that defendant asserted general denial to all of alleged sexual acts); State v. Voyles, 284 Kan. 239, 253 , 160 P.3d 794 (2007) (‘‘Kansas appellate courts have held a ‘failure to instruct’ in multiple acts cases to be reversible error except when the defen- dant presents a unified defense, e.g., a general denial.

2025See, e.g., State v. Moyer, 306 Kan. 342 , 358–63, 410 P.3d 71 (2017) (any error in court’s failure to instruct jury that it had to be unanimous as to specific act of fellatio that constituted criminal sodomy was harmless given that defendant asserted general denial to all of alleged sexual acts); State v. Voyles, 284 Kan. 239, 253 , 160 P.3d 794 (2007) (‘‘Kansas appellate courts have held a ‘failure to instruct’ in multiple acts cases to be reversible error except when the defen- dant presents a unified defense, e.g., a general denial.

12025–2025
State v. Haley green
moctapp · 2017
1 sentence

2025Stated in the language of the clearly erroneous standard of review applicable when no unanimity instruction has been requested, cases not containing a unified defense are reversed because the reviewing court is firmly convinced that there is a real possibility the jury would have returned a different verdict if the instruction had been given.’’); State v. Escobar, 523 S.W.3d 545 , 552–53 (Mo. App. 2017) (when defendant denied allegations of sexual abuse as whole, argued that victim fabricated story and presented no incident-specific evidence to contest either of two specifically described inst

12025–2025
Edward L. Hoeber v. State of Missouri green
mo · 2016
1 sentence

2025Stated in the language of the clearly erroneous standard of review applicable when no unanimity instruction has been requested, cases not containing a unified defense are reversed because the reviewing court is firmly convinced that there is a real possibility the jury would have returned a different verdict if the instruction had been given.’’); State v. Escobar, 523 S.W.3d 545 , 552–53 (Mo. App. 2017) (when defendant denied allegations of sexual abuse as whole, argued that victim fabricated story and presented no incident-specific evidence to contest either of two specifically described inst

12025–2025

Where else courts name it

CA 217 (1987–2026) CT 13 (1991–2025) KS 12 (2007–2026) IL 8 (1996–2020) NY 6 (1985–2025) GA 6 (1969–2021) FL 5 (1983–2010) DE 4 (2010–2023) MA 4 (2011–2025) TX 4 (2010–2019) OK 4 (2004–2006) ID 3 (1987–2011) NH 3 (1972–1993) DC 3 (1974–1988) OR 3 (1992–2025) WI 3 (1992–2005) WA 2 (1986–2015) ME 2 (1980–1989) MN 2 (2017–2026) NM 2 (2017–2017)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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