## Facts

- Reginald Jones, age 17, was charged with murder in the Judicial District of New Haven and gave notice he might assert a defense of mental disease or defect.
- Years earlier, a private firm (Sperandeo, Weinstein & Donegan) represented Jones in a civil action arising from a 1966 automobile accident; the case settled in 1970.
- The firm’s file from the civil matter contained medical reports and related materials concerning Jones’s accident injuries, including possible head injury.
- Richard P. Sperandeo was simultaneously (1) Chief Assistant State’s Attorney in New Haven and (2) a partner in the private firm that had represented Jones in the civil matter.
- In 1978, another partner, Harold C. Donegan, briefly represented Jones’s father on an unrelated property-damage claim; that representation ended after the murder charge and disqualification motion.
- Donegan provided Jones’s criminal counsel all medical reports from the earlier civil file with authorization, but did not produce the entire file.
- The trial court found Sperandeo had not reviewed the civil file since 1970 and had not participated in, discussed, or accessed the criminal prosecution file.
- The trial court ordered Sperandeo to have no contact with the prosecution but refused to disqualify him formally and refused to disqualify the entire state’s attorney’s office.
- Jones pursued an interlocutory appeal challenging the denial of broader disqualification.

## Issues

1. Whether Sperandeo had to be disqualified from prosecuting Jones due to his firm’s prior representation of Jones in a matter substantially related to Jones’s intended mental-disease/defect defense.
2. Whether Sperandeo’s conflict (if any) required disqualification of all prosecutors in the New Haven state’s attorney’s office.
3. Whether Donegan’s separate, unrelated representation of Jones’s father created a disqualifying conflict affecting the prosecution.

## Decision

- The court reversed in part and affirmed in part.
- Sperandeo was required to be formally disqualified because the earlier civil representation and the criminal case were substantially related given the asserted mental-disease/defect defense tied to the same head injury.
- The court affirmed the denial of office-wide disqualification because the record did not show the prosecution office obtained confidential information, was tainted, or was advantaged by the prior representation.
- Donegan’s prior representation of Jones’s father in an unrelated property-damage matter did not support disqualification in the absence of a substantial relationship to the criminal prosecution.

## Legal Principles

- A lawyer’s former-client conflict warrants disqualification when the prior matter is substantially related to the current matter and confidential information from the former representation is materially relevant to issues in the current case.
- In prosecutor-conflict disputes, disqualification may be limited to the conflicted prosecutor; office-wide disqualification is not automatic and depends on whether the office had access to confidential information or gained an unfair advantage.
- Representation of a defendant’s relative in a separate, unrelated matter does not itself create a disqualifying conflict absent a substantial relationship to the prosecution or access to material confidential information.

## Conclusion

The court held that a prosecutor whose firm previously represented the defendant in a substantially related matter must be disqualified, but declined to disqualify the entire prosecutor’s office where the record showed no access to confidences, no advantage to the prosecution, and no participation by the conflicted prosecutor in the case.


State v. Jones, 180 Conn. 443, 429 A.2d 936 (Conn. 1980)