State v. Michael R.
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The Supreme Court affirmed the judgment of the trial court convicting Defendant of employing a minor in an obscene performance in violation of Conn. Gen. Stat. 53a-196a, sexual assault in the first degree, and other offenses, holding that Defendant was not entitled to relief on his claims of error.
Specifically, the Supreme Court held (1) the trial court did not abuse its discretion in denying Defendant's motion to sever the sexual offenses with the nonsexual offenses and in joining the informations for trial; (2) the obscene performance statute was not unconstitutionally vague as applied to Defendant's conduct, and the First Amendment did not require the Court to undertake an independent appellate review of that conviction; (3) the trial court's potentially incorrect rulings, including those relating to the excludion from evidence video recordings of forensic interviews of the victim, were harmless error beyond a reasonable doubt; and (4) the evidence was sufficient to support Defendant's convictions of assault in the third degree, criminal violation of a protective order, and stalking in the first degree.
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