isolated error in Connecticut

2019See Hunter v. Hamilton County Board of Elections , supra, at 234-37 ; cf. Northeast Ohio Coalition for Homeless v. Husted , 696 F.3d 580 , 597-98 (6th Cir. 2012) (finding sufficient evidence of purposeful conduct given state's "intent to enforce its strict disqualification rules without exception, despite the systemic poll-worker error identified in this litigation and others," which had "result[ed] in the rejection of thousands of provisional ballots each year").

2019See Hunter v. Hamilton County Board of Elections, supra, 234–37; cf. Northeast Ohio Coalition for Homeless v. Husted, 696 F.3d 580 , 597–98 (6th Cir. 2012) (finding sufficient evidence of purposeful conduct given state’s ‘‘intent to enforce its strict disqualifica- tion rules without exception, despite the systemic poll-worker error identi- fied in this litigation and others,’’ which had ‘‘result[ed] in the rejection of thousands of provisional ballots each year’’).

2020The United States Supreme Court has observed that ‘‘while in some instances even an isolated error can support an ineffective-assistance claim if it is sufficiently egregious and prejudicial . . . it is difficult to establish ineffective assistance when counsel’s overall performance indicates active and capable advocacy.’’ (Citation omitted; internal quota- tion marks omitted.) Harrington v. Richter, 562 U.S. 86, 111 , 131 S. Ct. 770 , 178 L.

2020The United States Supreme Court has observed that ‘‘while in some instances even an isolated error can support an ineffective-assistance claim if it is sufficiently egregious and prejudicial . . . it is difficult to establish ineffective assistance when counsel’s overall performance indicates active and capable advocacy.’’ (Citation omitted; internal quota- tion marks omitted.) Harrington v. Richter, 562 U.S. 86, 111 , 131 S. Ct. 770 , 178 L.

2022In People v. Clamuextle, 255 Ill.

2022Because of the difficulties inherent in making the evalu- ation, a court must indulge a strong presumption that counsel’s conduct falls within the wide range of reason- able professional assistance.’’ (Internal quotation marks omitted.) Meletrich v. Commissioner of Correction, 332 Conn. 615, 627 , 212 A.3d 678 (2019). ‘‘[I]n some instances even an isolated error can support an ineffective-assis- tance claim if it is sufficiently egregious and prejudicial . . . [but] it is difficult to establish ineffective assis- tance when counsel’s overall performance indicates active and capable advocacy.’’

2022Because of the difficulties inherent in making the evalu- ation, a court must indulge a strong presumption that counsel’s conduct falls within the wide range of reason- able professional assistance.’’ (Internal quotation marks omitted.) Meletrich v. Commissioner of Correction, 332 Conn. 615, 627 , 212 A.3d 678 (2019). ‘‘[I]n some instances even an isolated error can support an ineffective-assis- tance claim if it is sufficiently egregious and prejudicial . . . [but] it is difficult to establish ineffective assis- tance when counsel’s overall performance indicates active and capable advocacy.’’

2022Because of the difficulties inherent in making the evalu- ation, a court must indulge a strong presumption that counsel’s conduct falls within the wide range of reason- able professional assistance.’’ (Internal quotation marks omitted.) Meletrich v. Commissioner of Correction, 332 Conn. 615, 627 , 212 A.3d 678 (2019). ‘‘[I]n some instances even an isolated error can support an ineffective-assis- tance claim if it is sufficiently egregious and prejudicial . . . [but] it is difficult to establish ineffective assis- tance when counsel’s overall performance indicates active and capable advocacy.’’

2020See, e.g., Balaas v. Hartford, supra, 126 Conn. 514 ; see also Walsh v. Stonington Water Pollution Control Authority, supra, 250 Conn. 457 ; Maykut v. Plasko, 170 Conn. 310, 314 , 365 A.2d 1114 (1976); O’Neill v. Carolina Freight Carriers Corp., 156 Conn. 613 , 617–18, 244 A.2d 372 (1968); Nair v. Thaw, 156 Conn. 445, 452 , 242 A.2d 757 (1968). 10 In his brief, the plaintiff commits the same error as the Appellate Court and suggests that the proper focus of the unreasonable use inquiry is the ‘‘dangerous condition,’’ in this case, the ‘‘retaining wall without a fence.’’ (Emphasis in original.)

2020See, e.g., Balaas v. Hartford, supra, 126 Conn. 514 ; see also Walsh v. Stonington Water Pollution Control Authority, supra, 250 Conn. 457 ; Maykut v. Plasko, 170 Conn. 310, 314 , 365 A.2d 1114 (1976); O’Neill v. Carolina Freight Carriers Corp., 156 Conn. 613 , 617–18, 244 A.2d 372 (1968); Nair v. Thaw, 156 Conn. 445, 452 , 242 A.2d 757 (1968). 10 In his brief, the plaintiff commits the same error as the Appellate Court and suggests that the proper focus of the unreasonable use inquiry is the ‘‘dangerous condition,’’ in this case, the ‘‘retaining wall without a fence.’’ (Emphasis in original.)

2020See, e.g., Balaas v. Hartford, supra, 126 Conn. 514 ; see also Walsh v. Stonington Water Pollution Control Authority, supra, 250 Conn. 457 ; Maykut v. Plasko, 170 Conn. 310, 314 , 365 A.2d 1114 (1976); O’Neill v. Carolina Freight Carriers Corp., 156 Conn. 613 , 617–18, 244 A.2d 372 (1968); Nair v. Thaw, 156 Conn. 445, 452 , 242 A.2d 757 (1968). 10 In his brief, the plaintiff commits the same error as the Appellate Court and suggests that the proper focus of the unreasonable use inquiry is the ‘‘dangerous condition,’’ in this case, the ‘‘retaining wall without a fence.’’ (Emphasis in original.)

2020See, e.g., Balaas v. Hartford, supra, 126 Conn. 514 ; see also Walsh v. Stonington Water Pollution Control Authority, supra, 250 Conn. 457 ; Maykut v. Plasko, 170 Conn. 310, 314 , 365 A.2d 1114 (1976); O’Neill v. Carolina Freight Carriers Corp., 156 Conn. 613 , 617–18, 244 A.2d 372 (1968); Nair v. Thaw, 156 Conn. 445, 452 , 242 A.2d 757 (1968). 10 In his brief, the plaintiff commits the same error as the Appellate Court and suggests that the proper focus of the unreasonable use inquiry is the ‘‘dangerous condition,’’ in this case, the ‘‘retaining wall without a fence.’’ (Emphasis in original.)

2020See, e.g., Balaas v. Hartford, supra, 126 Conn. 514 ; see also Walsh v. Stonington Water Pollution Control Authority, supra, 250 Conn. 457 ; Maykut v. Plasko, 170 Conn. 310, 314 , 365 A.2d 1114 (1976); O’Neill v. Carolina Freight Carriers Corp., 156 Conn. 613 , 617–18, 244 A.2d 372 (1968); Nair v. Thaw, 156 Conn. 445, 452 , 242 A.2d 757 (1968). 10 In his brief, the plaintiff commits the same error as the Appellate Court and suggests that the proper focus of the unreasonable use inquiry is the ‘‘dangerous condition,’’ in this case, the ‘‘retaining wall without a fence.’’ (Emphasis in original.)

2020See, e.g., Balaas v. Hartford, supra, 126 Conn. 514 ; see also Walsh v. Stonington Water Pollution Control Authority, supra, 250 Conn. 457 ; Maykut v. Plasko, 170 Conn. 310, 314 , 365 A.2d 1114 (1976); O’Neill v. Carolina Freight Carriers Corp., 156 Conn. 613 , 617–18, 244 A.2d 372 (1968); Nair v. Thaw, 156 Conn. 445, 452 , 242 A.2d 757 (1968). 10 In his brief, the plaintiff commits the same error as the Appellate Court and suggests that the proper focus of the unreasonable use inquiry is the ‘‘dangerous condition,’’ in this case, the ‘‘retaining wall without a fence.’’ (Emphasis in original.)

2014We are not persuaded. *51 As a threshold matter, the defendant concedes that he failed to preserve this claim on appeal, but nevertheless seeks reversal pursuant to State v. Golding, 213 Conn. 233, 239-40 , 567 A.2d 823 (1989). 2 Because the record is adequate and the claim is of constitutional magnitude, we will afford it review. 3 The following additional facts and procedural history are relevant to our disposition of this claim.

2014We are not persuaded. *51 As a threshold matter, the defendant concedes that he failed to preserve this claim on appeal, but nevertheless seeks reversal pursuant to State v. Golding, 213 Conn. 233, 239-40 , 567 A.2d 823 (1989). 2 Because the record is adequate and the claim is of constitutional magnitude, we will afford it review. 3 The following additional facts and procedural history are relevant to our disposition of this claim.

1990Where, however, an affidavit recites merely an isolated violation, the passage of time between the occurrence and the issuance of the warrant is significant and the probable cause may “[dwindle] rather quickly with the passage of time.” United States v. Johnson, supra; see also United States v. Martino, 664 F.2d 860 (2d Cir. 1981); State v. Garcia, 7 Conn. App. 354, 360-61 , 508 A.2d 824 (1986).

1990Where, however, an affidavit recites merely an isolated violation, the passage of time between the occurrence and the issuance of the warrant is significant and the probable cause may “[dwindle] rather quickly with the passage of time.” United States v. Johnson, supra; see also United States v. Martino, 664 F.2d 860 (2d Cir. 1981); State v. Garcia, 7 Conn. App. 354, 360-61 , 508 A.2d 824 (1986).

1990Where, however, an affidavit recites merely an isolated violation, the passage of time between the occurrence and the issuance of the warrant is significant and the probable cause may “[dwindle] rather quickly with the passage of time.” United States v. Johnson, supra; see also United States v. Martino, 664 F.2d 860 (2d Cir. 1981); State v. Garcia, 7 Conn. App. 354, 360-61 , 508 A.2d 824 (1986).