Singh violation (Connecticut) · Go Syfert
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Singh violation in Connecticut

12 Connecticut opinions name it 2 courts 2007–2024 1 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 (6)

CaseFollowedCited
State v. Singhgreen
conn · 2002 · cited in 4 Connecticut opinions naming this issue, 2017–2019
2 sentences

2019Although one of the problems arising from a Singh violation is that it risks distorting the state's burden of proof; see State v. Singh , supra, 259 Conn. at 709 -10 , 793 A.2d 226 ("such comments excluded possibility that jury could have concluded only that witnesses were probably truthful and defendant was probably lying, thereby preventing jury from 'return[ing] a verdict of not guilty because the evidence might not be sufficient to convict the defendant beyond a reasonable doubt' " [emphasis omitted] ), the fact that it was not directed at the state's key witness and had no impact on the c

2019Although one of the problems arising from a Singh violation is that it risks distorting the state's burden of proof; see State v. Singh , supra, 259 Conn. at 709 -10 , 793 A.2d 226 ("such comments excluded possibility that jury could have concluded only that witnesses were probably truthful and defendant was probably lying, thereby preventing jury from 'return[ing] a verdict of not guilty because the evidence might not be sufficient to convict the defendant beyond a reasonable doubt' " [emphasis omitted] ), the fact that it was not directed at the state's key witness and had no impact on the c

24
United States v. Sullivangreen
ca1 · 1996 · cited in 1 Connecticut opinions naming this issue, 2012–2012
1 sentence

2012See, e.g., State v. Fauci, supra, 282 Conn. 53 -54 (state’s case did not wholly rest on testimony of victims); State v. Ritrovato, supra, 280 Conn. 67 (state’s case was strong in light of signed confession); State v. Warholic, supra, 278 Conn. 404 (only one Singh violation on central issue of credibility and other improprieties were not central); State v. Stevenson, supra, 269 Conn. 591 -98 (defense invited improprieties, only two instances of impropriety, and independent physical evidence substantiated state’s allegations); cf. United States v. Sullivan, 85 F.3d 743, 750 (1st Cir. 1996) (ques

11
State v. Burtongreen
conn · 2001 · cited in 1 Connecticut opinions naming this issue, 2008–2008
2 sentences

2008See State v. Santiago, 269 Conn. 726, 743-44 , 850 A.2d 199 (2004) (no Singh violation when prosecutor merely summarized defendant’s argument that state witnesses must have lied); see also State v. Burton, 258 Conn. 153, 166-70 , 778 A.2d 955 (2001) (state properly may argue that state witnesses had no apparent motive to lie).

2008See State v. Santiago, 269 Conn. 726, 743-44 , 850 A.2d 199 (2004) (no Singh violation when prosecutor merely summarized defendant’s argument that state witnesses must have lied); see also State v. Burton, 258 Conn. 153, 166-70 , 778 A.2d 955 (2001) (state properly may argue that state witnesses had no apparent motive to lie).

11
State v. Santiagogreen
conn · 2004 · cited in 1 Connecticut opinions naming this issue, 2008–2008
2 sentences

2008See State v. Santiago, 269 Conn. 726, 743-44 , 850 A.2d 199 (2004) (no Singh violation when prosecutor merely summarized defendant’s argument that state witnesses must have lied); see also State v. Burton, 258 Conn. 153, 166-70 , 778 A.2d 955 (2001) (state properly may argue that state witnesses had no apparent motive to lie).

2008See State v. Santiago, 269 Conn. 726, 743-44 , 850 A.2d 199 (2004) (no Singh violation when prosecutor merely summarized defendant’s argument that state witnesses must have lied); see also State v. Burton, 258 Conn. 153, 166-70 , 778 A.2d 955 (2001) (state properly may argue that state witnesses had no apparent motive to lie).

11
UNITED STATES of America, Plaintiff-Appellee, v. Gabriel SANCHEZ-LIMA, Defendant-Appellantgreen
ca9 · 1998 · cited in 1 Connecticut opinions naming this issue, 2007–2007
1 sentence

2007Although these questions did not ask the defendant overtly to say whether a wdtness was wrong or mistaken, effectively, they essentially asked the same improper question, only phrased in the positive rather than in the negative. 25 See United States v. Freitag, 230 F.3d 1019, 1024 (7th Cir. 2000) (asking defendant if testimony of other witnesses is true is improper because it “invades the province of the jury; indeed asking if testimony is true implies that if it is not, it is a lie, which is a credibility question for the jury to decide”); see also United States v. Sanchez-Lima, 161 F.3d 545,

11
United States v. Georgia R. Freitaggreen
ca7 · 2000 · cited in 1 Connecticut opinions naming this issue, 2007–2007
1 sentence

2007Although these questions did not ask the defendant overtly to say whether a wdtness was wrong or mistaken, effectively, they essentially asked the same improper question, only phrased in the positive rather than in the negative. 25 See United States v. Freitag, 230 F.3d 1019, 1024 (7th Cir. 2000) (asking defendant if testimony of other witnesses is true is improper because it “invades the province of the jury; indeed asking if testimony is true implies that if it is not, it is a lie, which is a credibility question for the jury to decide”); see also United States v. Sanchez-Lima, 161 F.3d 545,

11

Distinguished, questioned or overruled (1)

CaseNegativeCited
State v. Ceballosgreen
conn · 2003 · cited in 1 Connecticut opinions naming this issue, 2012–2012
2 sentences

2012See State v. Angel T., supra, 292 Conn. 288 -89; State v. Stevenson, supra, 593-95 ; but see State v. Ceballos, 266 Conn. 364, 415 , 832 A.2d 14 (2003) (Singh violation was “sufficiently egregious to overcome the suggestion that defense counsel did not think it was unfair at the time”); State v. Singh, supra, 259 Conn. 723 (“[although many of the improprieties were not serious . . . the questions and comments about witnesses’ veracity” constituted “notable exceptions”); cf. State v. Warholic, 278 Conn. 354, 399 , 897 A.2d 569 (2006) (objection to Singh violation not dispositive of severity).

2012See State v. Angel T., supra, 292 Conn. 288 -89; State v. Stevenson, supra, 593-95 ; but see State v. Ceballos, 266 Conn. 364, 415 , 832 A.2d 14 (2003) (Singh violation was “sufficiently egregious to overcome the suggestion that defense counsel did not think it was unfair at the time”); State v. Singh, supra, 259 Conn. 723 (“[although many of the improprieties were not serious . . . the questions and comments about witnesses’ veracity” constituted “notable exceptions”); cf. State v. Warholic, 278 Conn. 354, 399 , 897 A.2d 569 (2006) (objection to Singh violation not dispositive of severity).

11

Also cited on this issue (6)

CaseCitedYears
State v. Warholic green
conn · 2006
2 sentences

2012See State v. Angel T., supra, 292 Conn. 288 -89; State v. Stevenson, supra, 593-95 ; but see State v. Ceballos, 266 Conn. 364, 415 , 832 A.2d 14 (2003) (Singh violation was “sufficiently egregious to overcome the suggestion that defense counsel did not think it was unfair at the time”); State v. Singh, supra, 259 Conn. 723 (“[although many of the improprieties were not serious . . . the questions and comments about witnesses’ veracity” constituted “notable exceptions”); cf. State v. Warholic, 278 Conn. 354, 399 , 897 A.2d 569 (2006) (objection to Singh violation not dispositive of severity).

2012See State v. Angel T., supra, 292 Conn. 288 -89; State v. Stevenson, supra, 593-95 ; but see State v. Ceballos, 266 Conn. 364, 415 , 832 A.2d 14 (2003) (Singh violation was “sufficiently egregious to overcome the suggestion that defense counsel did not think it was unfair at the time”); State v. Singh, supra, 259 Conn. 723 (“[although many of the improprieties were not serious . . . the questions and comments about witnesses’ veracity” constituted “notable exceptions”); cf. State v. Warholic, 278 Conn. 354, 399 , 897 A.2d 569 (2006) (objection to Singh violation not dispositive of severity).

22009–2012
State v. McCoy green
conn · 2019
2 sentences

2024The jury . . . could have found the defen- dant guilty on the basis of his testimony alone.’’), cert. denied, 335 Conn. 977 , 241 A.3d 131 (2020); State v. McCoy, 171 Conn. App. 311, 320 , 157 A.3d 97 (2017) (prosecutor’s argument that, ‘‘in order for the jurors to find that [a witness] had received a secret plea deal, they would need to find that several of the other wit- nesses had lied’’ was not improper under Singh because it ‘‘did not improperly present the jury with a choice between believing the state’s witnesses and [finding] the defendant [not guilty]’’), rev’d in part on other ground

2024The jury . . . could have found the defen- dant guilty on the basis of his testimony alone.’’), cert. denied, 335 Conn. 977 , 241 A.3d 131 (2020); State v. McCoy, 171 Conn. App. 311, 320 , 157 A.3d 97 (2017) (prosecutor’s argument that, ‘‘in order for the jurors to find that [a witness] had received a secret plea deal, they would need to find that several of the other wit- nesses had lied’’ was not improper under Singh because it ‘‘did not improperly present the jury with a choice between believing the state’s witnesses and [finding] the defendant [not guilty]’’), rev’d in part on other ground

12024–2024
State v. McCoy green
connappct · 2017
2 sentences

2024The jury . . . could have found the defen- dant guilty on the basis of his testimony alone.’’), cert. denied, 335 Conn. 977 , 241 A.3d 131 (2020); State v. McCoy, 171 Conn. App. 311, 320 , 157 A.3d 97 (2017) (prosecutor’s argument that, ‘‘in order for the jurors to find that [a witness] had received a secret plea deal, they would need to find that several of the other wit- nesses had lied’’ was not improper under Singh because it ‘‘did not improperly present the jury with a choice between believing the state’s witnesses and [finding] the defendant [not guilty]’’), rev’d in part on other ground

2024The jury . . . could have found the defen- dant guilty on the basis of his testimony alone.’’), cert. denied, 335 Conn. 977 , 241 A.3d 131 (2020); State v. McCoy, 171 Conn. App. 311, 320 , 157 A.3d 97 (2017) (prosecutor’s argument that, ‘‘in order for the jurors to find that [a witness] had received a secret plea deal, they would need to find that several of the other wit- nesses had lied’’ was not improper under Singh because it ‘‘did not improperly present the jury with a choice between believing the state’s witnesses and [finding] the defendant [not guilty]’’), rev’d in part on other ground

12024–2024
State v. Stevenson green
conn · 2004
2 sentences

2017The defendant did not invite the prosecutor to make the Singh violation comment because neither defense counsel’s theory of the case nor closing argu- ment pertained to the credibility of Angon or Medina.13 See State v. Stevenson, 269 Conn. 563, 593 , 849 A.2d 626 (2004) (comment invited because defendant’s theory of case was that police lied).

2017The defendant did not invite the prosecutor to make the Singh violation comment because neither defense counsel’s theory of the case nor closing argu- ment pertained to the credibility of Angon or Medina.13 See State v. Stevenson, 269 Conn. 563, 593 , 849 A.2d 626 (2004) (comment invited because defendant’s theory of case was that police lied).

12017–2017
State v. Williams green
conn · 1987
2 sentences

2015I would conclude that the Appellate Court properly applied the factors set forth in State v. Williams, 204 Conn. 523, 540 , 529 A.2d 653 (1987), and properly concluded that the improprieties, the existence of which the state con- cedes, deprived the defendant of a fair trial.

2015I would conclude that the Appellate Court properly applied the factors set forth in State v. Williams, 204 Conn. 523, 540 , 529 A.2d 653 (1987), and properly concluded that the improprieties, the existence of which the state con- cedes, deprived the defendant of a fair trial.

12015–2015
State v. Alexander green
conn · 2000
2 sentences

2015Cf. State v. Alexander, 254 Conn. 290, 305 , 755 A.2d 868 (2000) (prosecutorial vouching ‘‘is especially significant . . . [when] the credibility of the victim and the defendant comprise[s] the principal issue of the case’’).

2015Cf. State v. Alexander, 254 Conn. 290, 305 , 755 A.2d 868 (2000) (prosecutorial vouching ‘‘is especially significant . . . [when] the credibility of the victim and the defendant comprise[s] the principal issue of the case’’).

12015–2015

Statutes the citing opinions construe

CT § Conn. Gen. Stat. § 51-199 (4) CT § Conn. Gen. Stat. § 21a-278 (3) CT § Conn. Gen. Stat. § 53a-59 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

CT 12 (2007–2024) WI 7 (2014–2026) CA 7 (2013–2024) NY 2 (2004–2010) TX 2 (2022–2026) GA 2 (2014–2014)

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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