State of Connecticut v. Michael Anthony Guerrera

Summary

The court held that the Department of Correction recordings reviewed at the state's request were part of the state's investigation and therefore subject to Brady disclosure obligations, but the 1552 recordings preserved only in response to the defendant's subpoena were not part of that investigation. Because the defendant made no adequate showing that the unreviewed recordings were likely to contain exculpatory information, the state had no duty to review them or produce them for the defendant's inspection. The court affirmed the Appellate Court's judgment; McDonald, J., concurring, agreed with the result but emphasized that administrative burden cannot diminish the state's Brady obligations when evidence is within the state's investigatory file.