State of Connecticut v. Jeffrey P. Gould.

Summary

The court held that even assuming the trial court improperly excused a prospective juror because of insufficient English proficiency, the error was subject to harmless-error review rather than automatic reversal. A defendant must show that the ruling resulted in an identifiable, objectionable juror serving on the jury or otherwise deprived the defendant of an impartial jury; Gould made no such showing. Justice Espinosa, concurring, agreed with the result but would have held that the trial court's factual finding was not clearly erroneous and that the excusal was within its discretion.