four-pronged Golding test in Connecticut

2021The reason for this is that the touchstone for appellate review of claims of prosecu- torial [impropriety] is a determination of whether the defendant was deprived of his right to a fair trial, and this determination must involve the application of the factors set out by this court in State v. Williams, 204 Conn. 523, 540 , 529 A.2d 653 (1987).’’ (Internal quotation marks omitted.) State v. Spencer, 275 Conn. 171, 178 , 881 A.2d 209 (2005).

2021The reason for this is that the touchstone for appellate review of claims of prosecu- torial [impropriety] is a determination of whether the defendant was deprived of his right to a fair trial, and this determination must involve the application of the factors set out by this court in State v. Williams, 204 Conn. 523, 540 , 529 A.2d 653 (1987).’’ (Internal quotation marks omitted.) State v. Spencer, 275 Conn. 171, 178 , 881 A.2d 209 (2005).

2007“In cases of unpreserved claims of prosecutorial misconduct ... it is unnecessary for the defendant to seek to prevail under the specific requirements of [State v. Golding, 213 Conn. 233, 239-40 , 567 A.2d 823 (1989)] and, similarly, it is unnecessary for a reviewing court to apply the four-pronged Golding test.” (Internal quotation marks omitted.) State v. Spencer, 275 Conn. 171, 178 , 881 A.2d 209 (2005).

2007“In cases of unpreserved claims of prosecutorial misconduct ... it is unnecessary for the defendant to seek to prevail under the specific requirements of [State v. Golding, 213 Conn. 233, 239-40 , 567 A.2d 823 (1989)] and, similarly, it is unnecessary for a reviewing court to apply the four-pronged Golding test.” (Internal quotation marks omitted.) State v. Spencer, 275 Conn. 171, 178 , 881 A.2d 209 (2005).

2023Still angry, she threatened a lawsuit against him because he purportedly locked her and her two year old son out of the home after she failed to pay rent earlier that winter, claiming that he owed her three months of rent because of the lockout. 8 Although defense counsel did not object to the challenged remarks, ‘‘under settled law, a defendant who fails to preserve claims of prosecutorial [impropriety] need not seek to prevail under the specific requirements of State v. Golding, 213 Conn. 233 , 239–40, 567 A.2d 823 (1989), and, similarly, it is unnecessary for a reviewing court to apply the

2022It is only relevant to negate an element of the crime charged, such as intent.’’ 6 The Oxford English Dictionary defines ‘‘Occam’s razor’’ as ‘‘[t]he princi- ple that in explaining anything no more assumptions should be made than are necessary.’’ Oxford English Dictionary (3d Ed. 2004) (online version). 7 Although the defendant’s claims are unpreserved, ‘‘under settled law, a defendant who fails to preserve claims of prosecutorial [impropriety] need not seek to prevail under the specific requirements of State v. Golding, 213 Conn. 233 , 239–40, 567 A.2d 823 (1989), and, similarly, it is unnece

2019"It is well established law ... that a defendant who fails to preserve claims of prosecutorial [impropriety] need not seek to prevail under the specific requirements of State v. Golding , 213 Conn. 233 , 239-40, 567 A.2d 823 (1989), and, similarly, it is unnecessary for a reviewing court to apply the four-pronged Golding test." (Internal quotation marks omitted.) State v. Franklin , 175 Conn. App. 22 , 48, 166 A.3d 24 , cert. denied, 327 Conn. 961 , 172 A.3d 801 (2017).

2019"It is well established law ... that a defendant who fails to preserve claims of prosecutorial [impropriety] need not seek to prevail under the specific requirements of State v. Golding , 213 Conn. 233 , 239-40, 567 A.2d 823 (1989), and, similarly, it is unnecessary for a reviewing court to apply the four-pronged Golding test." (Internal quotation marks omitted.) State v. Franklin , 175 Conn. App. 22 , 48, 166 A.3d 24 , cert. denied, 327 Conn. 961 , 172 A.3d 801 (2017).

2019"It is well established law ... that a defendant who fails to preserve claims of prosecutorial [impropriety] need not seek to prevail under the specific requirements of State v. Golding , 213 Conn. 233 , 239-40, 567 A.2d 823 (1989), and, similarly, it is unnecessary for a reviewing court to apply the four-pronged Golding test." (Internal quotation marks omitted.) State v. Franklin , 175 Conn. App. 22 , 48, 166 A.3d 24 , cert. denied, 327 Conn. 961 , 172 A.3d 801 (2017).

2019"It is well established law ... that a defendant who fails to preserve claims of prosecutorial [impropriety] need not seek to prevail under the specific requirements of State v. Golding , 213 Conn. 233 , 239-40, 567 A.2d 823 (1989), and, similarly, it is unnecessary for a reviewing court to apply the four-pronged Golding test." (Internal quotation marks omitted.) State v. Franklin , 175 Conn. App. 22 , 48, 166 A.3d 24 , cert. denied, 327 Conn. 961 , 172 A.3d 801 (2017).

2025Moreover, he further testified that he could ‘‘honestly say that [he] did not do that to [L] . . . because [he knew he] wouldn’t.’’ Shortly there- after, the following colloquy between the prosecutor and the defendant took place: 18 ‘‘[U]nder settled law, a defendant who fails to preserve claims of prosecu- torial [impropriety] need not seek to prevail under the specific requirements of State v. Golding, 213 Conn. 233 , 239–40, 567 A.2d 823 (1989), and, similarly, it is unnecessary for a reviewing court to apply the four-pronged Golding test.’’ (Internal quotation marks omitted.) State v. Maur

2025Moreover, he further testified that he could ‘‘honestly say that [he] did not do that to [L] . . . because [he knew he] wouldn’t.’’ Shortly there- after, the following colloquy between the prosecutor and the defendant took place: 18 ‘‘[U]nder settled law, a defendant who fails to preserve claims of prosecu- torial [impropriety] need not seek to prevail under the specific requirements of State v. Golding, 213 Conn. 233, 239–40, 567 A.2d 823 (1989), and, similarly, it is unnecessary for a reviewing court to apply the four-pronged Golding test.’’ (Internal quotation marks omitted.) State v. Mauri

2025Page 32A CONNECTICUT LAW JOURNAL November 25, 2025 32 NOVEMBER, 2025 236 Conn. App. 428 State v. Antwon B. ‘‘[The Prosecutor]: [Y]ou heard [L].

2023Third, the defendant at oral argument before this court abandoned the aspect of his claim based on the third category of statements. 18 As an initial matter, we agree with both parties that it is immaterial whether the defendant’s one objection to the prosecutor’s use of the term ‘‘victim’’ preserved his prosecutorial impropriety claim because ‘‘under set- tled law, a defendant who fails to preserve claims of prosecutorial [impropri- ety] need not seek to prevail under the specific requirements of State v. Golding, [supra, 213 Conn. 239–40], and, similarly, it is unnecessary for a reviewing co

2023Third, the defendant at oral argument before this court abandoned the aspect of his claim based on the third category of statements. 18 As an initial matter, we agree with both parties that it is immaterial whether the defendant’s one objection to the prosecutor’s use of the term ‘‘victim’’ preserved his prosecutorial impropriety claim because ‘‘under set- tled law, a defendant who fails to preserve claims of prosecutorial [impropri- ety] need not seek to prevail under the specific requirements of State v. Golding, [supra, 213 Conn. 239–40], and, similarly, it is unnecessary for a reviewing co

2023Third, the defendant at oral argument before this court abandoned the aspect of his claim based on the third category of statements. 18 As an initial matter, we agree with both parties that it is immaterial whether the defendant’s one objection to the prosecutor’s use of the term ‘‘victim’’ preserved his prosecutorial impropriety claim because ‘‘under set- tled law, a defendant who fails to preserve claims of prosecutorial [impropri- ety] need not seek to prevail under the specific requirements of State v. Golding, [supra, 213 Conn. 239–40], and, similarly, it is unnecessary for a reviewing co

2021Because these claims require the application of distinct legal principles, we address them separately in this opinion. 10 In light of the Appellate Court’s express application of State v. Golding, 213 Conn. 233 , 239–40, 567 A.2d 823 (1989), as modified by In re Yasiel R., 317 Conn. 773 , 781, 120 A.3d 1188 (2015), to the claims raised by the defen- dant; see State v. Gonzalez, supra, 188 Conn. App. 318–19; we take this opportunity to reiterate that ‘‘a defendant who fails to preserve claims of prosecutorial [impropriety] need not seek to prevail under the specific requirements of [Golding] an

2021Because these claims require the application of distinct legal principles, we address them separately in this opinion. 10 In light of the Appellate Court’s express application of State v. Golding, 213 Conn. 233 , 239–40, 567 A.2d 823 (1989), as modified by In re Yasiel R., 317 Conn. 773 , 781, 120 A.3d 1188 (2015), to the claims raised by the defen- dant; see State v. Gonzalez, supra, 188 Conn. App. 318–19; we take this opportunity to reiterate that ‘‘a defendant who fails to preserve claims of prosecutorial [impropriety] need not seek to prevail under the specific requirements of [Golding] an

2021Because these claims require the application of distinct legal principles, we address them separately in this opinion. 10 In light of the Appellate Court’s express application of State v. Golding, 213 Conn. 233 , 239–40, 567 A.2d 823 (1989), as modified by In re Yasiel R., 317 Conn. 773 , 781, 120 A.3d 1188 (2015), to the claims raised by the defen- dant; see State v. Gonzalez, supra, 188 Conn. App. 318–19; we take this opportunity to reiterate that ‘‘a defendant who fails to preserve claims of prosecutorial [impropriety] need not seek to prevail under the specific requirements of [Golding] an

2019In this opinion the other judges concurred. 1 The video recording of that interview was admitted into evidence, along with a corresponding transcript. 2 The defendant pleaded guilty to the possession of narcotics with intent to sell and criminal possession of a revolver charges prior to trial. 3 Although the defendant did not object to the remarks he challenges on appeal, we still review his claims because ‘‘a defendant who fails to preserve claims of prosecutorial [impropriety] need not seek to prevail under the specific requirements of [State v. Golding, 213 Conn. 233 , 239–40, 567 A.2d 823

2019In this opinion the other judges concurred. 1 The video recording of that interview was admitted into evidence, along with a corresponding transcript. 2 The defendant pleaded guilty to the possession of narcotics with intent to sell and criminal possession of a revolver charges prior to trial. 3 Although the defendant did not object to the remarks he challenges on appeal, we still review his claims because ‘‘a defendant who fails to preserve claims of prosecutorial [impropriety] need not seek to prevail under the specific requirements of [State v. Golding, 213 Conn. 233 , 239–40, 567 A.2d 823

2019This rule, however, "does not pertain to mere evidentiary claims masquerading as constitutional violations." (Internal quotation marks omitted.) State v. Small , supra, 180 Conn. App. at 687 , 184 A.3d 816 .

2019This rule, however, "does not pertain to mere evidentiary claims masquerading as constitutional violations." (Internal quotation marks omitted.) State v. Small , supra, 180 Conn. App. at 687 , 184 A.3d 816 .

2019In this opinion the other judges concurred. 1 The video recording of that interview was admitted into evidence, along with a corresponding transcript. 2 The defendant pleaded guilty to the possession of narcotics with intent to sell and criminal possession of a revolver charges prior to trial. 3 Although the defendant did not object to the remarks he challenges on appeal, we still review his claims because ‘‘a defendant who fails to preserve claims of prosecutorial [impropriety] need not seek to prevail under the specific requirements of [State v. Golding, 213 Conn. 233 , 239–40, 567 A.2d 823

2019In this opinion the other judges concurred. 1 The video recording of that interview was admitted into evidence, along with a corresponding transcript. 2 The defendant pleaded guilty to the possession of narcotics with intent to sell and criminal possession of a revolver charges prior to trial. 3 Although the defendant did not object to the remarks he challenges on appeal, we still review his claims because ‘‘a defendant who fails to preserve claims of prosecutorial [impropriety] need not seek to prevail under the specific requirements of [State v. Golding, 213 Conn. 233 , 239–40, 567 A.2d 823

2019Although the defendant did not object to the prosecutor's remarks at trial, his claim is nonetheless reviewable because "a defendant who fails to preserve claims of prosecutorial [impropriety] need not seek to prevail under the specific requirements of [ Golding ], and, similarly, it is unnecessary for a reviewing *550 court to apply the four-pronged Golding test." (Internal quotation marks omitted.) State v. Papantoniou , 185 Conn. App. 93 , 110, 196 A.3d 839 (2018). "[O]ur Supreme Court has explained that a defendant's failure to object at trial to each of the occurrences that he now raises

2019Although the defendant did not object to the prosecutor's remarks at trial, his claim is nonetheless reviewable because "a defendant who fails to preserve claims of prosecutorial [impropriety] need not seek to prevail under the specific requirements of [ Golding ], and, similarly, it is unnecessary for a reviewing *550 court to apply the four-pronged Golding test." (Internal quotation marks omitted.) State v. Papantoniou , 185 Conn. App. 93 , 110, 196 A.3d 839 (2018). "[O]ur Supreme Court has explained that a defendant's failure to object at trial to each of the occurrences that he now raises

2018Golding and, similarly, it is unnecessary for a reviewing court to apply the four-pronged Golding test." (Internal quotation marks omitted.) State v. Bermudez , 274 Conn. 581 , 586-87, 876 A.2d 1162 (2005).

2018Golding and, similarly, it is unnecessary for a reviewing court to apply the four-pronged Golding test." (Internal quotation marks omitted.) State v. Bermudez , 274 Conn. 581 , 586-87, 876 A.2d 1162 (2005).

2015It requires that the criminal actor possess the specific intent to cause physical injury to another person.’’ (Internal quotation marks omitted.) State v. James E., 154 Conn. App. 795 , 804, 112 A.3d 791 (2015); State v. Sivak, 84 Conn. App. 105, 110 , 852 A.2d 812 , cert. denied, 271 Conn. 916 , 859 A.2d 573 (2004). 7 The defendant failed to object to the alleged improper statements during trial. ‘‘[I]n cases involving incidents of prosecutorial [impropriety] that were not objected to at trial . . . it is unnecessary for the defendant to seek to prevail under the specific requirements of [Sta

2015It requires that the criminal actor possess the specific intent to cause physical injury to another person.’’ (Internal quotation marks omitted.) State v. James E., 154 Conn. App. 795 , 804, 112 A.3d 791 (2015); State v. Sivak, 84 Conn. App. 105, 110 , 852 A.2d 812 , cert. denied, 271 Conn. 916 , 859 A.2d 573 (2004). 7 The defendant failed to object to the alleged improper statements during trial. ‘‘[I]n cases involving incidents of prosecutorial [impropriety] that were not objected to at trial . . . it is unnecessary for the defendant to seek to prevail under the specific requirements of [Sta

2015It requires that the criminal actor possess the specific intent to cause physical injury to another person.’’ (Internal quotation marks omitted.) State v. James E., 154 Conn. App. 795 , 804, 112 A.3d 791 (2015); State v. Sivak, 84 Conn. App. 105, 110 , 852 A.2d 812 , cert. denied, 271 Conn. 916 , 859 A.2d 573 (2004). 7 The defendant failed to object to the alleged improper statements during trial. ‘‘[I]n cases involving incidents of prosecutorial [impropriety] that were not objected to at trial . . . it is unnecessary for the defendant to seek to prevail under the specific requirements of [Sta

2015It requires that the criminal actor possess the specific intent to cause physical injury to another person.’’ (Internal quotation marks omitted.) State v. James E., 154 Conn. App. 795 , 804, 112 A.3d 791 (2015); State v. Sivak, 84 Conn. App. 105, 110 , 852 A.2d 812 , cert. denied, 271 Conn. 916 , 859 A.2d 573 (2004). 7 The defendant failed to object to the alleged improper statements during trial. ‘‘[I]n cases involving incidents of prosecutorial [impropriety] that were not objected to at trial . . . it is unnecessary for the defendant to seek to prevail under the specific requirements of [Sta

2014It is well established law, however, that “a defendant who fails to preserve claims of prosecutorial misconduct need not seek to prevail under the specific requirements of State v. Golding, 213 Conn. 233, 239-40 , 567 A.2d 823 (1989), and, similarly, it is unnecessary for a reviewing court to apply the four-pronged Golding test.” (Internal quotation marks omitted.) State v. Payne, 303 Conn. 538, 560 , 34 A.3d 370 (2012); see also State v. Stevenson, 269 Conn. 563, 572-75 , 849 A.2d 626 (2004); State v. Adams, 139 Conn. App. 540, 548 , 56 A.3d 747 (2012) (claim of prosecutorial impropriety may

2014It is well established law, however, that “a defendant who fails to preserve claims of prosecutorial misconduct need not seek to prevail under the specific requirements of State v. Golding, 213 Conn. 233, 239-40 , 567 A.2d 823 (1989), and, similarly, it is unnecessary for a reviewing court to apply the four-pronged Golding test.” (Internal quotation marks omitted.) State v. Payne, 303 Conn. 538, 560 , 34 A.3d 370 (2012); see also State v. Stevenson, 269 Conn. 563, 572-75 , 849 A.2d 626 (2004); State v. Adams, 139 Conn. App. 540, 548 , 56 A.3d 747 (2012) (claim of prosecutorial impropriety may

2008The reason for this is that the touchstone for appellate review of claims of prosecutorial [impropriety] is a determination of whether the defendant was deprived of his right to a fair trial, and this determination must involve the application of the factors set out by this court in State v. Williams, 204 Conn. 523, 540 , 529 A.2d 653 (1987).” (Internal quotation marks omitted.) State v. Smith, 107 Conn. App. 666, 681-82 , 946 A.2d 319 , cert. denied, 288 Conn. 902 , 952 A.2d 811 (2008). 5 In State v. Golding, supra, 213 Conn. 233 , our Supreme Court concluded that “a defendant can prevail on

2008The reason for this is that the touchstone for appellate review of claims of prosecutorial [impropriety] is a determination of whether the defendant was deprived of his right to a fair trial, and this determination must involve the application of the factors set out by this court in State v. Williams, 204 Conn. 523, 540 , 529 A.2d 653 (1987).” (Internal quotation marks omitted.) State v. Smith, 107 Conn. App. 666, 681-82 , 946 A.2d 319 , cert. denied, 288 Conn. 902 , 952 A.2d 811 (2008). 5 In State v. Golding, supra, 213 Conn. 233 , our Supreme Court concluded that “a defendant can prevail on

2008The reason for this is that the touchstone for appellate review of claims of prosecutorial [impropriety] is a determination of whether the defendant was deprived of his right to a fair trial, and this determination must involve the application of the factors set out by this court in State v. Williams, 204 Conn. 523, 540 , 529 A.2d 653 (1987).” (Internal quotation marks omitted.) State v. Smith, 107 Conn. App. 666, 681-82 , 946 A.2d 319 , cert. denied, 288 Conn. 902 , 952 A.2d 811 (2008). 5 In State v. Golding, supra, 213 Conn. 233 , our Supreme Court concluded that “a defendant can prevail on

2008The reason for this is that the touchstone for appellate review of claims of prosecutorial [impropriety] is a determination of whether the defendant was deprived of his right to a fair trial, and this determination must involve the application of the factors set out by this court in State v. Williams, 204 Conn. 523, 540 , 529 A.2d 653 (1987).” (Internal quotation marks omitted.) State v. Smith, 107 Conn. App. 666, 681-82 , 946 A.2d 319 , cert. denied, 288 Conn. 902 , 952 A.2d 811 (2008). 5 In State v. Golding, supra, 213 Conn. 233 , our Supreme Court concluded that “a defendant can prevail on