State v. Smith
807 A.2d 500, 2002 Conn. App. LEXIS 526, 73 Conn. App. 173 (2002)
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Rule of Law:
When a police officer claims self-defense for using deadly force under Conn. Gen. Stat. § 53a-22, the jury must evaluate the reasonableness of the officer's belief from the perspective of a 'reasonable police officer' in the same circumstances, not a generic 'reasonable person.' Evidence of the officer's training is relevant and generally admissible to help the jury apply this standard.
Facts:
- On December 29, 1998, police officer Scott Smith was informed that another officer was in foot pursuit of a suspect, Franklyn Reid.
- Smith and his partner located Reid and approached him in their vehicle, at which point Reid fled on foot.
- Smith pursued Reid across a busy road, repeatedly yelling, 'Stop, police.'
- Reid stopped in the middle of the road. Smith drew his weapon, ordered Reid to show his hands, and after Reid complied, moved him to a grassy area.
- Reid lay on his stomach, and Smith straddled him with his gun pointed at Reid's back to effect an arrest.
- Moments later, Smith fired a single shot into Reid's back, killing him.
- Witness testimony conflicted on whether Reid was struggling or had his hands secured behind his back when he was shot.
- A folding knife was later found in the pocket of a jacket Reid had been carrying.
Procedural Posture:
- The State of Connecticut charged Scott Smith with manslaughter in the first degree with a firearm.
- At a jury trial in the Connecticut Superior Court (trial court), Smith raised a justification defense, arguing his use of force was in self-defense.
- The trial court excluded the proposed testimony of several expert witnesses for the defense regarding police training and the use of deadly force.
- The trial court instructed the jury to evaluate the reasonableness of Smith's actions using a 'reasonable person' standard.
- The jury found Smith guilty of the charge.
- Smith (appellant) appealed the judgment of conviction to the Appellate Court of Connecticut, arguing the evidentiary rulings and jury instructions were improper.
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Issue:
Does a trial court's exclusion of expert testimony on police use-of-force training, coupled with a jury instruction based on a 'reasonable person' standard, violate a defendant police officer's constitutional right to present a complete self-defense claim?
Opinions:
Majority - Schaller, J.
Yes, the exclusion of such evidence and the improper jury instruction violate the defendant's right to present a defense. The court establishes a two-part subjective-objective test for evaluating a police officer's self-defense claim under § 53a-22. First, the jury must determine if the officer subjectively and honestly believed that deadly force was necessary. Second, the jury must determine if that belief was objectively reasonable from the perspective of a 'reasonable police officer' under the same circumstances. Because the 'reasonable police officer' standard involves specialized knowledge beyond that of an average juror, expert testimony on police training and use-of-force is crucial for the jury to make an informed decision. The trial court's exclusion of testimony from the defendant's police academy instructor, Reginald Allard, and its refusal to instruct the jury on the 'reasonable police officer' standard, instead using a 'reasonable person' standard, was an abuse of discretion that deprived the defendant of the meaningful opportunity to present a complete defense.
Analysis:
This decision establishes a critical legal distinction in Connecticut between self-defense claims made by civilians and those made by police officers. By adopting the 'reasonable police officer' standard from federal Fourth Amendment jurisprudence (Graham v. Connor), the court recognizes that an officer's training and experience shape their perception of a threat. This ruling mandates that trial courts allow expert testimony on police procedures to give context to an officer's actions, strengthening the procedural protections for law enforcement defendants. The case sets a precedent that juries cannot judge police conduct in a vacuum but must consider the specialized circumstances and training inherent in law enforcement.
