reasonable satisfaction standard in Connecticut

9 Connecticut opinions name it 2 courts 1993–1995 0 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)

Case	Followed	Cited
United States v. Javier Torrez-Floresgreen ca7 · 1980 · cited in 1 Connecticut opinions naming this issue, 1994–1994 1 sentence 1994See United States v. Torrez-Flores, 624 F.2d 776, 782 (7th Cir. 1980) (“court need only be ‘reasonably satisfied’ and need not find by a preponderance of the evidence that a violation has occurred”); United States v. Francischine, 512 F.2d 827, 829 (5th Cir. 1975) (“[pjrobably evidence rising to the level of substantial evidence is not even required ....	1	1
United States v. Frank David Francischinegreen ca5 · 1975 · cited in 1 Connecticut opinions naming this issue, 1994–1994 1 sentence 1994See United States v. Torrez-Flores, 624 F.2d 776, 782 (7th Cir. 1980) (“court need only be ‘reasonably satisfied’ and need not find by a preponderance of the evidence that a violation has occurred”); United States v. Francischine, 512 F.2d 827, 829 (5th Cir. 1975) (“[pjrobably evidence rising to the level of substantial evidence is not even required ....	1	1
United States v. Jose Guadarramagreen ca9 · 1984 · cited in 1 Connecticut opinions naming this issue, 1993–1993 1 sentence 1993In defining the standard of reasonable satisfaction, several courts have observed, “[t]he standard of proof required is that evidence and facts be such as reasonably to satisfy the judge that the probationer’s conduct has not been as required by the conditions of probation.” United States v. Czajak, supra, 22 , quoting United States v. Guadarrama, 742 F.2d 487, 489 (9th Cir. 1984).	1	1
United States v. Vance Smithgreen ca7 · 1978 · cited in 1 Connecticut opinions naming this issue, 1993–1993 1 sentence 1993United States v. Smith, 571 F.2d 370, 372 (7th Cir. 1978).	1	1

Distinguished, questioned or overruled (0)

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

Also cited on this issue (17)

Case	Cited	Years
State v. Davis green connappct · 1993 2 sentences 1994The standard of proof to be applied by the trial court in deciding whether a probationer has violated a condition of probation is the reasonable satisfaction standard, wherein the trial court must have a rational belief that the ‘evidence is adequate or sufficient to prove a violation.’ State v. Davis, 29 Conn. App. 801, 811 , 618 A.2d 557 (1993). ‘[0]ur review is limited to reviewing whether such a finding was clearly erroneous.’ Id., 805 .” State v. Carey, supra, 350 . 1994The standard of proof to be applied by the trial court in deciding whether a probationer has violated a condition of probation is the reasonable satisfaction standard, wherein the trial court must have a rational belief that the ‘evidence is adequate or sufficient to prove a violation.’ State v. Davis, 29 Conn. App. 801, 811 , 618 A.2d 557 (1993). ‘[0]ur review is limited to reviewing whether such a finding was clearly erroneous.’ Id., 805 .” State v. Carey, supra, 350 .	5	1993–1994
State v. Davis green conn · 1994 2 sentences 1994Our Supreme Court in State v. Davis, 229 Conn. 285 , 641 A.2d 370 (1994), held that the fair preponderance of the evidence standard is the appropriate standard of proof that the state must meet to establish a violation of a condition of probation. 1994Our Supreme Court in State v. Davis, 229 Conn. 285 , 641 A.2d 370 (1994), held that the fair preponderance of the evidence standard is the appropriate standard of proof that the state must meet to establish a violation of a condition of probation.	2	1994–1994
Santosky v. Kramer green scotus · 1982 2 sentences 1995Accordingly, the state filed a motion for articulation, asking that the trial court clarify whether it applied the fair preponderance of the evidence standard in determining that the state had proven a violation of probation. 7 The trial court did issue an articulation indicating that, although at the time of the hearing it believed that a reasonable satisfaction standard applied, there was “very little question” at the time of the hearing that a violation of probation had been established and that the violation of probation was proven “by at least a preponderance of the reliable and probative 1995Accordingly, the state filed a motion for articulation, asking that the trial court clarify whether it applied the fair preponderance of the evidence standard in determining that the state had proven a violation of probation. 7 The trial court did issue an articulation indicating that, although at the time of the hearing it believed that a reasonable satisfaction standard applied, there was “very little question” at the time of the hearing that a violation of probation had been established and that the violation of probation was proven “by at least a preponderance of the reliable and probative	1	1995–1995
Payne v. Robinson green conn · 1988 2 sentences 1994Finally, although the Appellate Court applied the reasonable satisfaction standard in State v. Johnson, 11 Conn. App. 251, 258 , 527 A.2d 250 (1987), and Payne v. Robinson, 10 Conn. App. 395, 403 , 523 A.2d 917 (1987), aff'd, 207 Conn. 565 , 541 A.2d 504 , cert. denied, 488 U.S. 898 , 109 S. Ct. 242 , 102 L. 1994Finally, although the Appellate Court applied the reasonable satisfaction standard in State v. Johnson, 11 Conn. App. 251, 258 , 527 A.2d 250 (1987), and Payne v. Robinson, 10 Conn. App. 395, 403 , 523 A.2d 917 (1987), aff'd, 207 Conn. 565 , 541 A.2d 504 , cert. denied, 488 U.S. 898 , 109 S. Ct. 242 , 102 L.	1	1994–1994
State v. Davis green conn · 1993 1 sentence 1994“The standard of proof to be applied by the trial court in deciding whether a probationer has violated a condition of probation is the reasonable satisfaction standard, wherein the trial court must have a rational belief that the ‘evidence is adequate or sufficient to prove a violation.’ State v. Davis, 29 Conn. App. 801, 811 , 618 A.2d 557 [cert. granted, 225 Conn. 918 , 623 A.2d 1024 ] (1993).” State v. Carey, 30 Conn. App. 346, 350 , 620 A.2d 201 , cert. granted, 225 Conn. 922 , 625 A.2d 823 (1993).	1	1994–1994
Fortier v. Newington Group, Inc. green conn · 1993 1 sentence 1994“The standard of proof to be applied by the trial court in deciding whether a probationer has violated a condition of probation is the reasonable satisfaction standard, wherein the trial court must have a rational belief that the ‘evidence is adequate or sufficient to prove a violation.’ State v. Davis, 29 Conn. App. 801, 811 , 618 A.2d 557 [cert. granted, 225 Conn. 918 , 623 A.2d 1024 ] (1993).” State v. Carey, 30 Conn. App. 346, 350 , 620 A.2d 201 , cert. granted, 225 Conn. 922 , 625 A.2d 823 (1993).	1	1994–1994
Metro Bulletins Corp. v. Soboleski green conn · 1993 1 sentence 1994“The standard of proof to be applied by the trial court in deciding whether a probationer has violated a condition of probation is the reasonable satisfaction standard, wherein the trial court must have a rational belief that the ‘evidence is adequate or sufficient to prove a violation.’ State v. Davis, 29 Conn. App. 801, 811 , 618 A.2d 557 [cert. granted, 225 Conn. 918 , 623 A.2d 1024 ] (1993).” State v. Carey, 30 Conn. App. 346, 350 , 620 A.2d 201 , cert. granted, 225 Conn. 922 , 625 A.2d 823 (1993).	1	1994–1994
Black v. London & Egazarian Associates, Inc. green conn · 1993 1 sentence 1994“The standard of proof to be applied by the trial court in deciding whether a probationer has violated a condition of probation is the reasonable satisfaction standard, wherein the trial court must have a rational belief that the ‘evidence is adequate or sufficient to prove a violation.’ State v. Davis, 29 Conn. App. 801, 811 , 618 A.2d 557 [cert. granted, 225 Conn. 918 , 623 A.2d 1024 ] (1993).” State v. Carey, 30 Conn. App. 346, 350 , 620 A.2d 201 , cert. granted, 225 Conn. 922 , 625 A.2d 823 (1993).	1	1994–1994
State v. Johnson green connappct · 1987 2 sentences 1994Finally, although the Appellate Court applied the reasonable satisfaction standard in State v. Johnson, 11 Conn. App. 251, 258 , 527 A.2d 250 (1987), and Payne v. Robinson, 10 Conn. App. 395, 403 , 523 A.2d 917 (1987), aff'd, 207 Conn. 565 , 541 A.2d 504 , cert. denied, 488 U.S. 898 , 109 S. Ct. 242 , 102 L. 1994Finally, although the Appellate Court applied the reasonable satisfaction standard in State v. Johnson, 11 Conn. App. 251, 258 , 527 A.2d 250 (1987), and Payne v. Robinson, 10 Conn. App. 395, 403 , 523 A.2d 917 (1987), aff'd, 207 Conn. 565 , 541 A.2d 504 , cert. denied, 488 U.S. 898 , 109 S. Ct. 242 , 102 L.	1	1994–1994
Payne v. Robinson green connappct · 1987 2 sentences 1994Finally, although the Appellate Court applied the reasonable satisfaction standard in State v. Johnson, 11 Conn. App. 251, 258 , 527 A.2d 250 (1987), and Payne v. Robinson, 10 Conn. App. 395, 403 , 523 A.2d 917 (1987), aff'd, 207 Conn. 565 , 541 A.2d 504 , cert. denied, 488 U.S. 898 , 109 S. Ct. 242 , 102 L. 1994Finally, although the Appellate Court applied the reasonable satisfaction standard in State v. Johnson, 11 Conn. App. 251, 258 , 527 A.2d 250 (1987), and Payne v. Robinson, 10 Conn. App. 395, 403 , 523 A.2d 917 (1987), aff'd, 207 Conn. 565 , 541 A.2d 504 , cert. denied, 488 U.S. 898 , 109 S. Ct. 242 , 102 L.	1	1994–1994
State v. Carey green connappct · 1993 2 sentences 1994“The standard of proof to be applied by the trial court in deciding whether a probationer has violated a condition of probation is the reasonable satisfaction standard, wherein the trial court must have a rational belief that the ‘evidence is adequate or sufficient to prove a violation.’ State v. Davis, 29 Conn. App. 801, 811 , 618 A.2d 557 [cert. granted, 225 Conn. 918 , 623 A.2d 1024 ] (1993).” State v. Carey, 30 Conn. App. 346, 350 , 620 A.2d 201 , cert. granted, 225 Conn. 922 , 625 A.2d 823 (1993). 1994“The standard of proof to be applied by the trial court in deciding whether a probationer has violated a condition of probation is the reasonable satisfaction standard, wherein the trial court must have a rational belief that the ‘evidence is adequate or sufficient to prove a violation.’ State v. Davis, 29 Conn. App. 801, 811 , 618 A.2d 557 [cert. granted, 225 Conn. 918 , 623 A.2d 1024 ] (1993).” State v. Carey, 30 Conn. App. 346, 350 , 620 A.2d 201 , cert. granted, 225 Conn. 922 , 625 A.2d 823 (1993).	1	1994–1994
Daloia v. Rose green scotus · 1988 1 sentence 1994Finally, although the Appellate Court applied the reasonable satisfaction standard in State v. Johnson, 11 Conn. App. 251, 258 , 527 A.2d 250 (1987), and Payne v. Robinson, 10 Conn. App. 395, 403 , 523 A.2d 917 (1987), aff'd, 207 Conn. 565 , 541 A.2d 504 , cert. denied, 488 U.S. 898 , 109 S. Ct. 242 , 102 L.	1	1994–1994
Ochoa-Ochoa v. United States green scotus · 1988 1 sentence 1994Finally, although the Appellate Court applied the reasonable satisfaction standard in State v. Johnson, 11 Conn. App. 251, 258 , 527 A.2d 250 (1987), and Payne v. Robinson, 10 Conn. App. 395, 403 , 523 A.2d 917 (1987), aff'd, 207 Conn. 565 , 541 A.2d 504 , cert. denied, 488 U.S. 898 , 109 S. Ct. 242 , 102 L.	1	1994–1994
Plyler v. Evatt green scotus · 1988 1 sentence 1994Finally, although the Appellate Court applied the reasonable satisfaction standard in State v. Johnson, 11 Conn. App. 251, 258 , 527 A.2d 250 (1987), and Payne v. Robinson, 10 Conn. App. 395, 403 , 523 A.2d 917 (1987), aff'd, 207 Conn. 565 , 541 A.2d 504 , cert. denied, 488 U.S. 898 , 109 S. Ct. 242 , 102 L.	1	1994–1994
Schaffer v. Lindy green connappct · 1986 2 sentences 1993The axiom that, if a trial court does not state or imply it is using that proper standard of proof, a new trial is necessary; Schaffer v. Lindy, 8 Conn. App. 96, 105 , 511 A.2d 1022 (1986); applies only when the standard of proof that should have been used is higher than the preponderance of the evidence standard. 1993The axiom that, if a trial court does not state or imply it is using that proper standard of proof, a new trial is necessary; Schaffer v. Lindy, 8 Conn. App. 96, 105 , 511 A.2d 1022 (1986); applies only when the standard of proof that should have been used is higher than the preponderance of the evidence standard.	1	1993–1993
United States v. Ronald Czajak green ca1 · 1990 1 sentence 1993In defining the standard of reasonable satisfaction, several courts have observed, “[t]he standard of proof required is that evidence and facts be such as reasonably to satisfy the judge that the probationer’s conduct has not been as required by the conditions of probation.” United States v. Czajak, supra, 22 , quoting United States v. Guadarrama, 742 F.2d 487, 489 (9th Cir. 1984).	1	1993–1993
Gagnon v. Scarpelli red scotus · 1973 2 sentences 1993A probation revocation hearing is not a stage of a criminal prosecution; Gagnon v. Scarpelli, 411 U.S. 778, 782 , 93 S. Ct. 1756 , 36 L. 1993A probation revocation hearing is not a stage of a criminal prosecution; Gagnon v. Scarpelli, 411 U.S. 778, 782 , 93 S. Ct. 1756 , 36 L.	1	1993–1993

Statutes the citing opinions construe

CT § Conn. Gen. Stat. § 53a-32 (7) CT § Conn. Gen. Stat. § 52-180 (3) CT § Conn. Gen. Stat. § 53a-61 (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 9 (1993–1995) RI 6 (2005–2015)

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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