State v. Roman
CourtSupreme Court of Connecticut
Date FiledJuly 14, 2026
DocketSC20993
JudgeMullins; McDonald; D’Auria; Ecker; Alexander; Dannehy; Bright
StatusPublished
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Full Opinion
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State v. Roman
MULLINS, C. J., concurring in the judgment. I concur
in the result reached by the majority, which reverses the
judgment of conviction. I write separately to address a
concern that, in my view, warrants this court’s careful
attention in a future case that properly presents the
issue. That concern is that we are expanding the scope
of what is reversible under the plain error doctrine for
unpreserved claims involving the no adverse inference
jury instruction mandated by General Statutes § 54-84
(b). In cases too numerous to count, this court has been
clear that the plain error doctrine is a rule of revers-
ibility; see, e.g., State v. Kyle A., 348 Conn. 437, 445,
307 A.3d 249 (2024); and that plain error review should
be reserved for “truly extraordinary” circumstances.
(Internal quotation marks omitted.) Id., 448–49; see,
e.g., State v. Ruocco, 322 Conn. 796, 803, 144 A.3d 354
(2016). To meet that high hurdle, the defendant typically
must demonstrate that (1) there was an obvious error,
and (2) failure to reverse the conviction would result in
manifest injustice. See, e.g., State v. Blaine, 334 Conn.
298, 306, 221 A.3d 798 (2019). In Ruocco, however,
this court explained that, under the second prong of
the plain error test for unpreserved claims involving
the no adverse inference instruction, the state is usu-
ally required to demonstrate that the omission of the
instruction was harmless beyond a reasonable doubt.
See State v. Ruocco, supra, 804–805 n.3. I question
whether, for purposes of plain error, that remains the
appropriate test to apply to an unpreserved claim that
the trial court violated § 54-84 (b). Specifically, I am not
convinced that, after State v. Kitchens, 299 Conn. 447,
482–83, 10 A.3d 942 (2011), and State v. McClain, 324
Conn. 802, 812, 815, 155 A.3d 209 (2017), we should be
applying the harmless error standard to an unpreserved
instructional error claim.1
In Kitchens, this court concluded that a criminal defen-
dant’s unpreserved claim of instructional error is deemed
1
I agree with the majority that Ruocco was not the first time that
this court had conducted a harmless error analysis when it had been
asked to review these types of unpreserved instructional error claims
State v. Roman
implicitly waived and, therefore, is not subject to review
under State v. Golding, 213 Conn. 233, 239–40, 567
A.2d 823 (1989), when, as in the present case, defense
counsel has had a meaningful opportunity to review the
proposed instructions. See State v. Kitchens, supra,
299 Conn. 482–83. Then, in McClain, we clarified that
a Kitchens waiver limited the review available for an
unpreserved instructional error claim to reversal for
plain error if the defendant shows that the error is clear
and that a failure to reverse the judgment would result
in manifest injustice. See State v. McClain, supra, 324
Conn. 812, 815.
Yet, in considering an unpreserved claim of trial
court noncompliance with § 54-84 (b) after Kitchens
was decided, this court concluded, without mentioning
Kitchens, that “[t]he applicable test requires the state
to prove beyond a reasonable doubt that, from the view-
point of the charge as a whole, there is no reasonable
possibility that the jury was misled.” (Internal quota-
tion marks omitted.) State v. Ruocco, supra, 322 Conn.
804. Accordingly, Ruocco applied the harmless error
standard applicable under Golding to an unpreserved
instructional error claim that would not be entitled to
Golding review due to a Kitchens waiver. The majority
refers to this incongruity as a “doctrinal idiosyncrasy
. . . .” Part II B 2 of the majority opinion. I doubt the
wisdom of continuing this course.
Nevertheless, because the parties have not challenged
this court’s conclusion in Ruocco, I am constrained to
apply the test set forth in that case. Under that test, I
cannot conclude that there is no reasonable possibility
that the jury was misled. Accordingly, I concur in the
judgment.
under the plain error doctrine. See footnote 17 of the majority opinion
and accompanying text. In my view, however, the question is whether,
after Kitchens and McClain, an unpreserved instructional error claim
that has been implicitly waived is still subject to harmless error analy-
sis. I think that we need to reconcile Ruocco and its predecessors with
Kitchens and McClain.