State v. Badgett

In State v. Badgett, 200 Conn. 412, 512 A.2d 160, cert. denied, 479 U.S. 940 (1986) the Court found that a canvass lacking the term "jury trial" was sufficient under the circumstances to apprise the defendant of his right to a jury trial. Id. In Badgett, however, the defendant's prior experience with criminal proceedings, his representation by counsel and his election of a jury trial during his original plea of not guilty made it clear that he understood that he had a right to a jury trial. Id. The Court concluded that the trial court's express mention of waiver of the right to trial, combined with the defendant's prior election of a jury trial, his experience with criminal proceedings and apparent adequate representation by counsel, satisfy the constitutional requirement that a defendant be informed of the right to a jury trial. See id., 420 (holding that attorney may waive defendant's constitutional right to be informed of his right to jury trial).