Incriminating cell phone evidence was wrongly presented to jurors at Sergio Correa’s sensational triple murder trial, but the state Supreme Court on Friday let the convictions and life sentence stand, concluding other evidence was so overwhelming he would have been convicted regardless.
“We conclude that the evidence against the defendant, viewed cumulatively and in context, was strong, independent of the improperly admitted cell phone evidence,” the court concluded in a unanimous opinion.
“Although the cell phone evidence may have been important, it was not critical to the state’s case against the defendant. Accordingly, we are not persuaded that the improper admission of evidence from the cell phone’s contents contributed to or substantially affected the jury’s verdict.”
Correa, with his sister Ruth, committed one of the most brutal and depraved crimes in state history. In December 2017, Correa agreed to pay heroin addict Matthew Lindquist with cash and drugs for guns, a car and other goods. At the time, Matthew Lindquist was living with his parents, Kenneth and Janet, at the couples’ home in rural Griswold.
Sergio Correa, with his public defenders Maureen Murphy, left, and Joseph E. Lopez Sr., in Superior Court in New London on the first day of his probable cause hearing. Correa was later convicted in the murders of three members of the Lindquist family in Griswold in 2017.
After driving to Griswold — following a route provided by a cell phone app and tracked by cellular tower traffic — Correa and his sister double-crossed Matthew Lindquist, hacking him with a machete, stabbing him 67 times and leaving his body covered with leaves in the eastern Connecticut woods.
Correa then entered the parents’ house in the hours after midnight. He and his sister beat Kenneth and Janet Lindquist to death with a baseball bat and a golf club, strangled Janet Lindquist with shoelace to make sure she was dead and stole whatever they could carrying from the house — including wrapped Christmas presents — before burning the house to the ground.
Ruth Correa later agreed to cooperate with the prosecution and testified against her brother.
Matthew’s body was not discovered for months and detectives, aware of his addiction and his strained relationship with his parents, considered him a suspect. But they learned early in the investigation from examining Matthew’s cell phone, which Correa stole and carried back to his apartment in Hartford, that Matthew was acquainted with Correa and had been corresponding with him about selling guns and a car before the murders.
The state police seized Correa’s phone, to preserve it as evidence, before Matthew’s body had been found and while he was still a suspect. The Supreme Court said in its decision that it “assumed” that seizure was legal.
In the decision written by Justice Andrew McDonald, the court devoted most of its attention to a trial court decision that allowed prosecutors to present, as trial evidence against Correa, data from his cellphone. Detectives had been obtained a warrant to extract the data from the telephone.
Correa’s public defenders challenged all evidence from the Correa phone in the run up to the trial and later on appeal.
The defense challenged the warrantless seizure that took place while Matthew Lindquist was still alive. And it challenged data later extracted from the phone, arguing the search warrant failed to link the data detectives hoped to find with specific charges against Correa and that the warrant should have limited the data to be extracted to a limited time period.
The prosecution claimed on appeal that detectives were justified in seizing the phone because Correa would have destroyed it otherwise. The prosecutors said the warrant obtained later for data extraction was supported by charges outlined in a related affidavit and that cellphone technology is not capable of extracting data according to date.”
The court agreed with the defense position.
“In sum, we conclude that the warrant violated the defendant’s fourth amendment right because it lacked particularity by failing to limit the type of content to be searched and seized or to provide any time parameters,” the court said.
Had Correa’s cell phone data been eliminated as trial evidence, he still would have faced other significant cellular evidence, including data from Ruth’s phone, Matthew’s phone, the phones Correa stole from Kenneth and Janet Lindquist, and cellphone tower data.
With admissible cell phone and tower data, state police detectives were able to track Correa and his sister from their apartment complex in Hartford, to the Lindquist house and back to Hartford.
It appeared that Correa was planning at a minimum to rob Matthew Lindquist and was concerned more about being captured by video surveillance than cellphone data.
When Matthew Lindquist first offered, in a text message exchange, to sell his car and his father’s guns to Correa, he suggested they meet in the parking lot of a store near the Lindquist home.
Correa rejected the parking lot, complaining, “too many cameras.” He said he would be driving a car registered to him. They decided on a wooded area, where Matthew Lindquist was hacked and stabbed to death near his parents’ home.
Another camera captured Ruth, with a large knife tucked into her jeans, as she left her Hartford apartment and prepared to drive to Griswold with her brother.
Correa stole Mathew Lindquist’s car and video surveillance footage captured him and his sister stopping in Glastonbury to burn and abandon it on the return trip from Griswold to Hartford.
Correa and his sister were convicted of a variety of murder, arson, robbery and home invasion charges. He was sentenced three years ago to 105 years in prison without possibility of parole. Ruth Correa was sentenced to 40 years after testifying against her brother.
