State of Connecticut v. Michael Anthony Guerrera

Summary

The court held that the Department of Correction's duty to review and disclose potentially favorable evidence extended only to recordings it actually reviewed at the state's request, because only those recordings became part of the state's investigation. The 1552 unreviewed recordings were preserved solely in response to the defendant's subpoena and remained records maintained for institutional purposes, so the state had no Brady duty to review or produce them absent a showing that they likely contained exculpatory information. The judgment affirming the defendant's convictions was affirmed. McDONALD, J., concurring, agreed with the result but emphasized that the burden of reviewing investigative records cannot diminish the state's disclosure obligation.