State v. Matheney

Convicted of intentional manslaughter in the first degree with a firearm, among other crimes, in connection with the shooting death of the victim, the defendant appealed to this court. After following the victim in his vehicle for a short distance, the defendant approached the driver's side of the victim's parked vehicle, exchanged insults with the victim, and then reached into the vehicle to grab a BB gun that the victim had with him. After a struggle dur- ing which the victim regained possession of the BB gun, the defendant drew his own gun and shot the victim. At trial, the defendant asserted a claim of self-defense. In response, the state argued, inter alia, that the defendant's self-defense claim failed because he did not reasonably believe that he faced the imminent use of physical force and because, under the circumstances of this case, the defendant was disqualified by statute (§ 53a-19 (b) and (c)) from claiming that self-defense justified his actions insofar as he had a duty to retreat, had provoked the victim, and had been the initial aggressor. On appeal, the defendant claimed, inter alia, that the trial court had erred when it failed to instruct the jurors that they must agree unanimously as to which specific statutory disqualification to self-defense the state established under § 53a-19 (b) or (c). Held: The defendant could not prevail on his unpreserved claim that the trial court had violated his constitutional right to a unanimous verdict by failing to instruct the jury that, in order to reject the defendant's claim of self-defense, it must unanimously agree as to which specific disqualification under § 53a- 19 (b) or (c) the state had established. Relying on its reasoning in State v. Mekoshvili (344 Conn. 673), in which the court held that there is generally no constitutional requirement that a jury be unanimous as to which of the specific components of a defendant's self-defense claim the state has disproven in order for the state to overcome that self-defense claim, this court held in the present case that, in general, so long as the jurors unanimously agree that the state has established a statu- tory disqualification to the assertion of a claim of self-defense, the federal constitution does not require them to be unanimous as to the particular statutory disqualification or disqualifications the state has established. Contrary to the defendant's claim, the trial court did not lead the jury to believe that only the defendant, and not the victim, could be the initial aggressor when it instructed the jury on the law of self-defense, as the court's instructions, as a whole, made abundantly clear that the victim could have been the initial aggressor. State v. Matheney The defendant could not prevail on his unpreserved claim that the trial court's charge failed to inform the jury that it could not find him to be the initial aggressor on the basis of his words alone and that this omission caused the jury to believe that the defendant was the initial aggressor simply because the defendant had initiated a verbal confrontation with the victim, as there was no suggestion by the court in its instructions, or by the state during the trial, that the person who was the initial aggressor had threatened the other person on the basis of words alone. There was no merit to the defendant's unpreserved claim that the trial court had misled the jury as to the state of mind required to find him guilty of certain recklessness-based lesser included offenses of murder because of the trial court's instructional summary document, which informed the jury in what sequence it should "deliberate" with respect to the recklessness-based lesser included offenses, as there was no reasonable possibility that the jury misconstrued the verb "deliberate" in that document as an adjective mean- ing "intentional," especially in light of the trial court's clear, concise, and complete verbal instructions on the recklessness-based offenses. The state presented sufficient evidence to satisfy its burden of disproving the defendant's claim of self-defense beyond a reasonable doubt, as the jury reasonably could have found, on the basis of the evidence presented, that the defendant did not actually or reasonably believe that the victim was using or was about to use deadly physical force against him, or was inflicting or about to inflict great bodily harm, or that deadly physical force was neces- sary to defend himself. The evidence was sufficient to establish that the defendant had acted with the specific intent necessary to support his conviction of intentional man- slaughter in the first degree with a firearm, as the jury reasonably could have found that he had intended to cause serious physical injury to the victim in view of the eyewitness testimony and the fact that the defendant had shot the victim at close range. Argued October 30, 2025—officially released February 17, 2026

Q: What was the main issue on appeal in State v. Matheney?

The main issue on appeal was whether the trial court made errors in admitting certain evidence and in its jury instructions that prejudiced Mr. Matheney and warranted overturning his conviction.

Q: Did the appellate court agree with Mr. Matheney's claims about the evidence?

The appellate court reviewed the evidence admitted and found that the trial court did not commit a clear abuse of discretion, and therefore, the admission of the evidence was not grounds for overturning the conviction.

Q: Were the jury instructions found to be flawed?

The appellate court found the jury instructions to be accurate and understandable to a reasonable juror, and therefore upheld them.

Q: What was the final outcome of the appeal?

The appellate court upheld Mr. Matheney's conviction, finding that the alleged trial errors were not significant enough to require a new trial or overturn the jury's verdict.

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