State v. Stankowski
184 Conn. 121, 439 A.2d 918, 1981 Conn. LEXIS 519 (1981)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
A conviction for murder may be sustained on circumstantial evidence of intent if the cumulative effect of the evidence, including the defendant's statements, conduct with the weapon, and verbal threats, is sufficient for a jury to reasonably infer a conscious objective to cause death beyond a reasonable doubt.
Facts:
- On August 25, 1977, after consuming alcohol and marijuana with friends, Gary Stankowski invited several people, including Valerie Vickers, to his house.
- While driving to the house, Stankowski told a friend that he 'really did not like Valerie.'
- At the house, Stankowski and a friend went to a shed where Stankowski retrieved a .12 gauge shotgun and was heard rustling through shells, despite being told not to 'mess around' with them.
- Upon returning to a loft where the group had gathered, others heard Stankowski making noises with the shotgun consistent with it 'being cocked and opened up.'
- Another friend, Harold Corey, told Stankowski he was being 'reckless' with the gun and asked him to put it away.
- Stankowski pointed the shotgun at Vickers and told her he was going to shoot her.
- After Vickers responded, 'go ahead,' Stankowski fired the shotgun, killing her.
Procedural Posture:
- Gary Stankowski was charged with murder and tried before a jury in a Connecticut trial court.
- At the close of the state's case, Stankowski moved for a judgment of acquittal, which the trial court denied.
- At the close of all evidence, Stankowski again moved for acquittal, which was also denied.
- The jury returned a verdict finding Stankowski guilty of murder.
- After the verdict, Stankowski filed post-trial motions for acquittal and for a new trial, both of which the trial court denied.
- Stankowski (appellant) appealed the judgment to the Supreme Court of Connecticut, the state's highest court.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Is circumstantial evidence, including the defendant's prior statements of dislike, retrieval and loading of a weapon, and verbal threat to the victim, sufficient to establish the element of 'intent to cause death' for a murder conviction beyond a reasonable doubt?
Opinions:
Majority - Arthur H. Healey, J.
Yes. A jury's finding of intent for a murder conviction can be based on circumstantial evidence. The court must view the evidence in the light most favorable to sustaining the verdict, and it is the jury's role to weigh witness credibility. Intent is a mental process that can ordinarily be proven only by circumstantial evidence, and the jury's conclusion regarding intent should stand unless it is unreasonable. Here, the jury could have reasonably inferred Stankowski's intent to kill from the cumulative evidence: (1) his statement that he did not like the victim; (2) his actions of obtaining shells and loading the shotgun despite admonitions; (3) his pointing the loaded weapon at the victim; (4) his explicit statement that he was going to shoot her; and (5) physical evidence that contradicted his claim of an accidental shooting. Although the evidence was not overwhelming, it was sufficient to support the verdict.
Analysis:
This case reaffirms the critical principle that a defendant's subjective intent, a required element for many serious crimes like murder, can be proven entirely through circumstantial evidence. The court's decision highlights the high degree of deference appellate courts grant to a jury's role in assessing witness credibility and drawing reasonable inferences from the facts presented. This precedent solidifies the method by which prosecutors can build a case for specific intent by aggregating various pieces of evidence—such as prior statements, preparatory actions, and verbal threats—to collectively establish the defendant's state of mind beyond a reasonable doubt.
