State of Connecticut v. Jeffrey P. Gould.

Summary

The court held that an allegedly improper excusal of a prospective juror for insufficient English proficiency is not automatically reversible error; the defendant must show that the excusal prejudiced the impartiality of the jury that actually decided the case. The court rejected treating the excusal as equivalent to a discriminatory peremptory strike or structural error and affirmed because the defendant made no showing of prejudice. Justice Espinosa, concurring, agreed with the result but would have upheld the trial court's factual finding under the clearly erroneous standard.