In Connecticut v. Jones, 234 Conn. 324, 662 A.2d 1199 (Conn. 1995), the Court held that evidence that Jones refused to submit blood, hair, and saliva samples did not support an inference of consciousness of guilt.
The Court held:
Under the facts and circumstances of this case, where the defendant, on the basis of his religious beliefs, and with some success, took proper advantage of our legal process to challenge the state's efforts to compel the taking of nontestimonial evidence, where the defendant allowed an investigator to take the evidence without the need to use physical compulsion and where the results of the tests on the evidence have absolutely no probative value of the defendant's guilt, the court may not instruct the jury that it may draw the inference that the defendant's conduct is evidence of a guilty conscience. (Id. at 1216.)