State v. Ramsey (Conn. 2025): Clarifying the Appellate Test for Sufficiency of the Evidence where Self-Defense is Asserted

Introduction

In State v. Ramsey, 208 A.3d ___ (Conn. 2025), the Supreme Court of Connecticut confronted a familiar yet persistently contentious issue: When a defendant admits the physical act of killing but claims justification, what quantum and quality of evidence must the State marshal to defeat a self-defense claim, and how should an appellate court evaluate a post-verdict challenge to sufficiency of that proof?

Garry Ramsey was convicted of murdering Robert Callahan after conceding that he stabbed the victim but maintaining that he acted in self-defense. On appeal, Ramsey argued that the State failed to disprove self-defense—specifically, that it did not establish either the “duty-to-retreat” or “initial aggressor” statutory exceptions. The Supreme Court affirmed, holding that an appellate court may sustain a conviction so long as any one of the statutory elements of self-defense is negated beyond a reasonable doubt; the State need not also prove a statutory exception.

Beyond resolving the fate of Ramsey’s conviction, the Court articulated and applied a tidy rule for appellate review: if the record, viewed in the light most favorable to sustaining the verdict, supports a finding that the defendant (i) lacked a subjective belief in imminent deadly force, (ii) held an objectively unreasonable belief, (iii) actually but unreasonably believed deadly force was necessary, or (iv) any other § 53a-19 component fails, the conviction stands—regardless of duty-to-retreat or initial aggressor arguments.

Summary of the Judgment

• Holding. The evidence sufficed to allow the jury to reject Ramsey’s self-defense claim because it could reasonably find either that he did not honestly believe the victim was about to use deadly force, or that such belief was objectively unreasonable. Having so concluded, the Court declined to examine the “duty to retreat” and “initial aggressor” exceptions.
• Result. Murder conviction affirmed; 35-year sentence undisturbed.
• Key Evidentiary Points.
  • Testimony of Tiffany Menendez that the victim was unarmed and calm seconds before the fight.
  • Jailhouse testimony of Jerome Campbell that Ramsey admitted bringing the knife and repeatedly stabbing until he heard Callahan “gasp for air.”
  • Defensive wounds on the victim’s arms and lack of injuries on Ramsey.
  • Ramsey’s immediate flight, disposal of the knife, and post-incident concealment—deemed consciousness of guilt evidence.

Analysis

A. Precedents Cited and Their Influence

1. State v. O’Bryan, 318 Conn. 621 (2015) — established the dual subjective/objective test for deadly-force self-defense. The Court in Ramsey leans heavily on O'Bryan to frame the four statutory components.
2. State v. Hughes, 341 Conn. 387 (2021) — clarified the role of “consciousness of guilt” evidence and the sufficiency standard. Ramsey applies Hughes to justify reliance on post-crime conduct (flight, disposal of weapon).
3. State v. Mekoshvili, 344 Conn. 673 (2022) — held that jury unanimity is not required as to the specific self-defense component negated. Ramsey extends this logic to sufficiency review.
4. State v. Johnson, 351 Conn. 53 (2025) — reiterated that the State may defeat self-defense by disproving any single component and that appellate courts examine the record accordingly. Ramsey fortifies this approach.
5. State v. Revels, 313 Conn. 762 (2014) — classifies self-defense as a justification (not affirmative) defense, thus assigning the burden of disproving it to the prosecution. This framework undergirds the entire Ramsey analysis.

B. The Court’s Legal Reasoning

1. Step 1: Identify the Elements in Dispute. Ramsey’s appeal focused on two statutory exceptions, but the Court first asked whether the record supported a finding that the basic elements of § 53a-19 failed.
2. Step 2: Apply the Four-Element Matrix. Using the subjective/objective dichotomy, the Court concluded that ample evidence undermined at least two of the four elements:
   • Lack of an honest belief: Campbell’s testimony indicated Ramsey brought the knife intending to use it.
   • Lack of an objectively reasonable belief: Disparity in size, victim’s defensive wounds, victim’s initial calm, and Ramsey’s possession of the only knife made any resort to deadly force unreasonable.
3. Step 3: Consciousness of Guilt. Flight, weapon disposal, and vehicle cleaning bolstered inference that Ramsey knew his conduct was unjustified.
4. Step 4: Jury Instruction Harmony. The trial court instructed on all four elements plus two exceptions. This ensured the jury had a complete legal framework. Appellate review confirmed the instructions accurately tracked statute and precedent.
5. Step 5: Appellate Sufficiency Standard. Echoing Hughes, the Court reiterated that it is not enough for the defendant to point to an alternative innocent inference; the question is whether any reasonable view of the evidence supports the verdict.
6. Step 6: Exceptions Rendered Moot. Because the basic elements failed, analysis of duty to retreat or initial aggressor was unnecessary. This is the doctrinal crux: once any component collapses, exceptions need not be considered.

C. Likely Impact on Connecticut Self-Defense Jurisprudence

• Streamlined Appellate Review. Defendants challenging sufficiency on self-defense grounds must now grapple with the reality that an appellate court may affirm if any component is unsupported—rendering targeted attacks on specific statutory exceptions hazardous.
• Evidentiary Strategy at Trial. Prosecutors can focus resources on undermining the core components (subjective/objective belief) rather than proving exceptions, which often require additional factual predicates (e.g., retreat paths, initial provocations).
• Jury Instruction Practice. While Mekoshvili said unanimity is not constitutionally required on specific components, Ramsey tacitly approves trial courts providing a full menu of elements and exceptions—as long as they clarify that disproving any one suffices.
• Consciousness of Guilt Affirmed. Post-crime conduct remains a potent tool to negate self-defense, especially where physical evidence (weapon disposal, lack of injuries) dovetails with testimonial inconsistencies.
• Reinforcement of the Objective Reasonableness Test. The Court’s emphasis on victim/defendant size disparity, witness demeanor observations, and injury patterns provides practical metrics for future litigants assessing the reasonableness prong.

Complex Concepts Simplified

Self-Defense vs. Affirmative Defense

In Connecticut, self-defense is a “justification” defense. The defendant need only raise it; the State must then disprove it beyond a reasonable doubt. An affirmative defense reverses that burden.

Subjective / Objective Belief

Self-defense depends on what the defendant actually believed (subjective) and whether a reasonable person in the same circumstances would share that belief (objective). Failure on either prong defeats the defense.

Statutory Exceptions

Even if all four elements are satisfied, a defendant may still lose if:

• He could retreat with complete safety (duty to retreat), or
• He provoked or initiated the confrontation (initial aggressor).

Ramsey teaches that courts need not reach these if the basic elements themselves falter.

Consciousness of Guilt Evidence

Actions like fleeing, hiding evidence, or lying can signal that the actor knows he did wrong, helping jurors infer intent and negate self-defense claims.

Unanimity on Components

The jury need not agree which component the State disproved—only that the defense fails in some respect. This stems from Mekoshvili.

Standard of Review: Sufficiency of the Evidence

Appellate courts adopt the view of the evidence most favorable to the verdict. They ask whether any rational trier of fact could have reached the same conclusion.

Conclusion

State v. Ramsey sharpened Connecticut’s doctrine at the intersection of self-defense and appellate sufficiency review. The key takeaways are:

• The State carries the burden to negate self-defense, but may meet that burden by toppling any one of the four statutory components; it need not also prove an exception.
• Appellate courts, reviewing in the light most favorable to the verdict, will affirm if any reasonable inference supports the jury’s rejection of self-defense.
• Consciousness of guilty conduct (flight, weapon disposal) remains probative against self-defense.
• Trial courts may, and likely should, instruct on all components and exceptions, but juror unanimity as to which component fails is unnecessary.

Practitioners should note that the strategic battleground in self-defense cases will increasingly center on the subjective/objective reasonableness of the defendant’s belief, rather than on proving retreat paths or provocation histories. Ramsey stands as a modern template for evaluating and arguing such disputes in Connecticut criminal courts.