The Connecticut Appellate Court upheld the conviction of Brandt Sanderson for risk of injury to a child, affirming the trial court's decision regarding prearrest delay. This ruling affects individuals facing similar charges and clarifies the standards for due process claims in Connecticut.
On June 2, 2026, the court released its opinion in the case of State v. Sanderson (AC47622), where the defendant appealed his conviction following a conditional plea of nolo contendere. Sanderson argued that his due process rights were violated due to a nearly twenty-year delay between the alleged crime and his arrest.
Background
Brandt Sanderson, a former youth pastor, was charged with risk of injury to a child under General Statutes § 53-21 (a) (2). The charges stemmed from incidents that occurred between June 2002 and January 2003, when the victim was fourteen years old. The allegations included inappropriate sexual contact that escalated over time.
The police first learned about the allegations in March 2019, when a friend of the victim reported the abuse. Following this report, the investigation took over three years, culminating in Sanderson's arrest in August 2022. The lengthy delay in executing the arrest warrant became a central issue in Sanderson's appeal.
The Ruling
The court, consisting of Judges Elgo, Suarez, and Seeley, ruled that the trial court properly denied Sanderson's motion to dismiss the charges based on prearrest delay. The court stated, "The defendant did not establish that the prearrest delay caused him actual and substantial prejudice," which is a requirement under Connecticut law.
The court referenced the precedent set in State v. McFarland, which established that defendants must demonstrate actual and substantial prejudice to claim a violation of due process due to prearrest delay. The judges declined to create an exception to this rule, reinforcing the necessity of proving specific harm caused by the delay.
Impact
This ruling has significant implications for future cases involving claims of prearrest delay in Connecticut. It emphasizes the burden on defendants to prove actual prejudice rather than relying on the mere passage of time. This decision may deter similar claims from being successful if defendants cannot provide concrete evidence of how the delay affected their ability to mount a defense.
Moreover, the court's decision clarifies the legal standards surrounding due process claims in the context of prearrest delays. It reinforces that the state's reasons for delays, including the complexities of investigations, will be weighed against the defendant's claims of prejudice.
What's Next
Sanderson's conviction can be appealed to the Connecticut Supreme Court, though it is unclear if he will pursue this option. There are no related cases pending that directly impact this ruling, but the decision may influence future legal arguments regarding prearrest delays in similar cases.