Connecticut Case Could Have Major Effect on Confidentiality of Married Couples’ Conversations in Criminal Cases Across U.S.
A state supreme court in Connecticut recently handed down a decision that may influence judges, as well as lawmakers, in states throughout the U.S.
Prosecutors in Connecticut brought murder charges against Sheila Davalloo in 2012. It was alleged that Davalloo killed Anna-Lisa Raymundo a decade earlier in an attempt to remove Raymundo as competition for another suitor.
According to prosecutors in the murder case, Davalloo beat and stabbed the victim at the victim’s residence in Stamford, CT. Davalloo reportedly knew the victim because they worked together at Purdue Pharma, a pharmaceutical company located in Stamford, Connecticut. The motive for the killing was said to be Davalloo’s jealousy over a sexual relationship between the victim and another person who worked at the drug company.
At the time of Raymundo’s death, Davalloo was actually married to another man. Between the time of the homicide and the time of the trial, Davalloo and her husband got divorced. Davalloo and her husband reportedly had a falling out after she allegedly stabbed him with a knife during a “game” at their residence in Pleasantville, NY. She was later convicted of the attempted murder of her husband, who then agreed to testify against her in the murder case.
Once prosecutors filed the criminal homicide charges against Davalloo, the case proceeded to trial. During the trial, the prosecution’s main witness was Davalloo’s ex-husband, who took the stand and testified about admissions made by Davalloo. The incriminating statements were a major factor in the jury’s ultimate decision to render a guilty verdict at the conclusion of the trial.
The testimony of Davalloo’s ex-husband revolved around statements made while the pair was still married. As a result, the testimony presented a problem for the prosecution. After all, weren’t Davalloo’s statements, made to her husband while they were married, protected by marital communications privilege laws? That was certainly the argument made by Davalloo’s defense lawyers in the case.
The trial court judge decided that Davalloo’s incriminating statements, which implicated Davalloo in the love-triangle murder, were not protected by spousal privilege. The trial ended with the jury convicting Davalloo and the judge sentencing her to serve 50 years behind bars.
Davalloo appealed the ruling, with the appeal going all the way up the legal ladder to the Connecticut Supreme Court. Now the state supreme court has upheld the lower court decision. When issuing its ruling, the CT Supreme Court stated that the husband’s testimony, which largely amounted to hearsay testimony since he testified about statements actually made by his wife, were not protected under spousal privilege because they were not “induced by the affection, confidence, loyalty and integrity of the marital relationship.”
This decision could have major implications for marital communications privilege in other states, including New Jersey. NJ law currently recognizes spousal privilege in the New Jersey Rules of Evidence. The Connecticut ruling could lead NJ judges and lawmakers to reconsider the scope of marital privilege in future criminal cases.
For additional information about the possible implications of the Connecticut spousal privilege case, check out the Yahoo.com article, “Court: Killer’s Conversations with Husband Not Confidential.”
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