expanded inquiry in Connecticut

2009State v. Doe, supra, at 609 , 765 A.2d 518 ." (Internal quotation marks omitted.) The majority reasons that the legislature presumably was aware of Doe when it amended § 54-63c(b) in 2007; Public Acts 2007, No. 07-123; yet the legislature did not amend the statute to require a full evidentiary hearing, or even an expanded hearing such as the majority now concludes is required.

2007In State v. Santiago, 245 Conn. 301, 336-40 , 715 A.2d 1 (1998), the court expanded the inquiry that must be conducted in cases in which racial bias is alleged, reasoning that "[a]llegations of racial bias on the part of a juror are fundamentally different from other types of juror misconduct, because such conduct is, ipso facto, prejudicial." Id., at 336 , 715 A.2d 1 .

2007In State v. Santiago, 245 Conn. 301, 336-40 , 715 A.2d 1 (1998), the court expanded the inquiry that must be conducted in cases in which racial bias is alleged, reasoning that "[a]llegations of racial bias on the part of a juror are fundamentally different from other types of juror misconduct, because such conduct is, ipso facto, prejudicial." Id., at 336 , 715 A.2d 1 .

2002The Court expanded that rule, holding that "steadfast refusal to change a situation known to cause an intrusion on the property of others satisfied the requirement of a showing of a `positive act,' since the prolonged continuation of the status quo with knowledge of the results evidenced a choice by the town to let the condition exist." Accashian v. City of Danbury , No. X01 CV 97 0147228S, 2000 Ct. Sup. 1114 , 1118 (Jan. 27, 2000, Hodgson, J.) In the Fourth Count of the Complaint the plaintiffs allege that the nuisance was created by the "negligent disposing of toxic and hazardous substances

1996Zuckerman v. Board of Zoning Appeals, 144 Conn. 160, 164 , 128 A.2d 325 (1956).

1996Zuckerman v. Board of Zoning Appeals, 144 Conn. 160, 164 , 128 A.2d 325 (1956).

1979This is not inconsistent with the recent holding in State v. Dolphin, 178 Conn. 564 , 424 A.2d 266 (1979), where this court expanded the rule relating to prior consistent statements to allow their admission, not only to rehabilitate an inconsistent statement offered to rebut a witness’ testimony, but also to admit them where the witness was impeached on the basis of bias, motive or interest so long as such consistent statement was made prior to the time when any motive, interest or bias arose.

1979This is not inconsistent with the recent holding in State v. Dolphin, 178 Conn. 564 , 424 A.2d 266 (1979), where this court expanded the rule relating to prior consistent statements to allow their admission, not only to rehabilitate an inconsistent statement offered to rebut a witness’ testimony, but also to admit them where the witness was impeached on the basis of bias, motive or interest so long as such consistent statement was made prior to the time when any motive, interest or bias arose.