Background
Tyquan Turner was convicted of felony murder, first-degree robbery, and conspiracy to commit first-degree robbery for the 2013 shooting death of Miguel Rodriguez in Hartford. The state’s evidence included eyewitness testimony, evidence connecting Turner to proceeds from the sale of the victim’s jewelry, and historical cell-site location information (CSLI) from a phone identified as Turner’s.
A police sergeant used the CSLI to create a GeoTime video that portrayed a human silhouette moving in straight lines among locations associated with the crime, including the shooting scene and pawn shop. The underlying CSLI, however, could establish only that the phone was somewhere within a cell-site coverage area; it could not identify a precise location, trace a route, or show who possessed the phone. Trial counsel neither objected to the video nor meaningfully challenged the CSLI evidence. The habeas court vacated Turner’s convictions and ordered a new trial.
The Court’s Holding
The Connecticut Supreme Court affirmed. It held that trial counsel rendered deficient performance by failing to challenge or otherwise respond to the misleading GeoTime video, which actively overstated what the CSLI could show. Although counsel’s general plan to focus on weaknesses in the eyewitness identifications and downplay CSLI was not objectively unreasonable, he did not carry out that strategy in closing or through any other meaningful challenge.
The court also found prejudice under Strickland. The state’s case was not overwhelming, the eyewitness identifications were weak, and the prosecutor described the phone evidence as the state’s strongest evidence and relied heavily on the video in closing and rebuttal. There was a reasonable probability of a different result had counsel undermined the misleading video and related CSLI presentation.
Key Takeaways
- A visual presentation of CSLI may be misleading when it depicts precise locations or travel that the underlying data cannot establish.
- A reasonable trial strategy must be meaningfully executed; merely intending to use an expert’s concessions in closing is insufficient.
- A habeas petitioner need not call the trial witness again or present new CSLI evidence when the claimed deficiency is counsel’s failure to challenge misleading evidence already apparent from the trial record.
Why It Matters
The decision underscores the special persuasive force of technical visual evidence. When an animation converts broad cell-site coverage data into an apparent depiction of a person’s movements, defense counsel must address the gap between the data’s limits and the visual’s implications.
For ineffective-assistance claims, the case confirms that prejudice may be shown where unchallenged expert evidence becomes the central evidentiary link in an otherwise non-overwhelming prosecution case.