Supreme Court of Connecticut

State v. Douglas C.

January 10, 2023

Summary

The court adopted a federal three-part test for determining whether a single criminal count based on multiple acts violates the constitutional requirement of jury unanimity. It held that the challenged counts were not duplicitous because the charged sexual contact either constituted a continuing course of conduct or occurred during a single criminal episode, so the lack of a specific unanimity instruction did not require reversal. The Appellate Court judgment was affirmed.