State of Connecticut v. Frank Schovanec

Summary

The court affirmed the defendant’s convictions and sentences, rejecting both his third-party culpability claim and his double-jeopardy challenge. The trial court properly excluded argument and declined to instruct the jury because the evidence concerning unidentified users of the stolen card in Waterbury did not directly connect them to the Newtown theft and card use. The multiple convictions also did not violate double jeopardy because the larceny conviction could have rested on separate conduct from the conduct supporting the identity-theft and illegal-credit-card-use convictions.