The Connecticut Appellate Court has upheld the decision to revoke Donyae Brown's probation, ruling that he was adequately notified of the charges against him. This ruling, made on November 3, 2026, affects Brown, who will now serve the remaining six and a half years of his suspended sentence. The case highlights the importance of due process rights in probation violation hearings.

The case, officially titled State of Connecticut v. Donyae Brown (AC48670), arose after Brown was convicted in 2020 for multiple offenses, including risk of injury to a child and burglary. He was sentenced to four years of incarceration, suspended after 18 months, followed by four years of probation. As part of his probation, he was required to comply with various conditions, including not violating any laws and attending substance abuse treatment.

On November 29, 2023, while on probation, Brown was arrested for several new charges, including violation of a restraining order and risk of injury to a child. Following this arrest, the state filed a motion on January 8, 2024, alleging that Brown had violated his probation. The basis for this violation included his failure to attend mandated substance abuse treatment sessions and testing positive for cocaine.

On January 23, 2025, the court held a hearing to address the alleged probation violations. On the morning of the hearing, the state submitted a substitute long form information, changing the basis for the alleged violation. Brown's defense attorney requested a continuance, arguing that the late filing of the substitute information deprived him of adequate time to prepare a defense. However, the court denied this request, stating that Brown had been aware of the claims six days prior to the hearing.

During the hearing, the court heard testimony from Brown's probation officer, Kimberly Lamothe, who outlined Brown's failures to comply with probation conditions. The defense did not present any witnesses or evidence, and after reviewing the case, the court found that Brown had indeed violated his probation.

In its ruling, the court addressed Brown's claim that his due process rights were violated due to the timing of the substitute information. The court noted that Brown had received written notice of the charges six days before the hearing and had ample opportunity to prepare. The judges, including Chief Judge Clark, concluded that the defendant's due process rights were not violated.

The court ruled, “the defendant failed to make a specific showing of prejudice resulting from the changes made in the substitute information.”

This decision is significant because it reinforces the standards for due process in probation violation hearings. The court emphasized that while defendants have the right to fair notice of the charges against them, they must also demonstrate specific prejudice resulting from any alleged violations of their rights.

The ruling could have implications for future probation violation cases in Connecticut, establishing a precedent that emphasizes the importance of timely notice while also requiring defendants to show how they were specifically harmed by any procedural changes. This case serves as a reminder that the courts will carefully consider the totality of the circumstances when determining whether due process rights have been upheld.

Looking ahead, Brown's legal team may consider further appeals, although the court's ruling appears to be firmly grounded in established legal principles regarding due process. There are no indications of related cases pending that would directly impact this ruling.