State v. Medrano
Trial courts are to refrain in the future from instructing jurors, when a defendant testifies, that they may specifically consider the defendant's interest in the outcome of the case and the importance to him of the outcome of the trial. For the stabbing death of Joel Quinones during a party and following a jury trial, Rafael Medrano was found not guilty of murder but guilty of the lesser included offense of intentional manslaughter in the first degree and carrying a dangerous weapon. The Appellate Court affirmed the conviction. Medrano appealed claiming that the prosecutor committed prosecutorial improprieties that deprived him of a fair trial and challenging the trial court's jury instruction that the defendant's interest in the outcome of the trial could be considered in evaluating his testimony. The Supreme Court affirmed the Appellate Court's judgment, finding that neither the instances of prosecutorial impropriety identified by the defendant, nor the trial court's instructions to the jury, affected the fairness of the trial or prejudiced the defendant. The unpreserved claim of instructional error was reviewed under the 1989 Supreme Court case of State v. Golding. The challenged instruction did not undermine the presumption of innocence or the defendant's rights under the federal and state constitutions to a fair trial and to testify in his own defense. The Supreme Court in 1991 upheld a similar charge in State v. Williams. As in Williams, the instruction here was evenhanded and not unduly repetitive. State v. Williams remained good law following the 2nd Circuit's 2006 decision in U.S. v. Gaines and 2007 decision in U.S. v. Brutus, concerning distinguishable charges. Furthermore, the fact that the defendant was acquitted of murder and convicted of first degree manslaughter demonstrated that the instruction did not violate his right to due process. Regardless of the challenged instruction, the jury found the defendant credible. He testified that he only intended to cut the victim and not kill him. Nevertheless, finding a risk of juror misunderstanding, the majority, exercising the Court's supervisory authority over the administration of justice, directed trial courts in the future to refrain from using the challenged instruction and instead to use a certain general credibility instruction. Justice Norcott, joined by Justices Zarella and Vertefeuille, concurred in the result, but disagreed with the use of supervisory powers to ban the instructions.