Supreme Court of Connecticut
State v. Ayala
February 7, 2017
Summary
The court held that a midtrial amendment adding factually distinct interference offenses violated the governing procedural rule because the state showed no good cause and the trial court failed to make the required finding. The violation was not structural or automatically reversible, but the state bore the burden of proving harmlessness beyond a reasonable doubt because the amendment implicated the defendant's constitutional notice right. The state could not meet that burden because the amendment occurred after the defendant had chosen to testify, potentially affecting that tactical and constitutional decision.