State v. Sayles
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The defendant, Dwayne Sayles, was convicted of felony murder and conspiracy to commit robbery in the first degree, among other crimes, in connection with his role in the robbery of a convenience store and the shooting death of the store clerk. On appeal, Sayles challenged the trial court's denial of his motions to suppress evidence of his cell phone and the data contained therein. He argued that the police had violated his rights under Miranda and the Connecticut constitution when they continued to interrogate him after he had invoked his right to counsel, and that the seizure of his cell phone violated the fourth amendment to the U.S. constitution and the Connecticut constitution.
However, the Supreme Court of Connecticut concluded that any error in the admission of the contents of Sayles' cell phone was harmless beyond a reasonable doubt due to the overwhelming wealth of evidence against him. This evidence included surveillance footage from inside of the convenience store, detailed testimony from a co-conspirator about Sayles' and his own involvement in the events, testimony from a jailhouse informant that Sayles had confessed to his involvement in the crimes, and a corroborating statement made to the police by a friend of Sayles. The court also noted significant evidence of Sayles' consciousness of guilt, such as testimony that he had directed his cousin to assault a potential witness to force him to recant his testimony. Physical evidence, including a ski mask and gloves found during the search of Sayles' residence and cell phone location data, further corroborated the testimony and statements. Given this, the court affirmed the Appellate Court’s judgment and declined to address Sayles' constitutional challenges.
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