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STATE v. SATURNO—CONCURRENCE
ZARELLA, J., concurring. I agree with the majority
that, because none of the claims raised by the defen-
dant, Donald Saturno, has merit, the judgment of the
trial court should be affirmed. I write separately, how-
ever, to reiterate my belief that the approach this court
adopted in State v. Geisler, 222 Conn. 672, 684–85, 610
A.2d 1225 (1992), for analyzing state constitutional
claims requires modification. As I stated in my concur-
rence in State v. Skok, 318 Conn. 699, 724, 122 A.3d
608 (2015), ‘‘[i]n my view, only three of the six factors
articulated in Geisler—the text of our constitution,
state constitutional history, and Connecticut prece-
dent—are consistently relevant. The other three factors
vary in their relevance. Although there may be occa-
sions when federal case law illuminates the meaning
of provisions in our state constitution, I believe the
precedent of our sister states and economic and socio-
logical considerations rarely, if ever, are useful for this
purpose.’’ Id., 725 (Zarella, J., concurring).
In the present case, the majority correctly concludes
that neither the text of the state constitution, its history,
nor our precedent supports the defendant’s claim under
article first, § 7, of the Connecticut constitution. The
majority nevertheless proceeds to consider the case
law of other jurisdictions, as well as economic and
sociological concerns, which I believe should play no
role in our resolution of the defendant’s claim. Accord-
ingly, I respectfully concur.