State of Connecticut v. Enrique Ayala

Summary

The court held that the trial court abused its discretion under Practice Book § 36-18 by permitting the state, after trial began, to add interference charges based on conduct at the police station without good cause and by charging additional offenses. That violation was not automatically reversible, because such an amendment is subject to harmless-error review, but the state failed to prove harmlessness beyond a reasonable doubt because the amendment occurred after the defendant testified and affected his choice and scope of testimony. The judgment reversing the convictions was therefore affirmed. ESPINOSA, J., dissenting, would have held that the amendment merely conformed the charges to the evidence, caused no prejudice, and was properly allowed.