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.