State of Connecticut v. Wright
2014 WL 1560708
Conn. App. Ct.2014Background
- Defendant Wright was convicted by a jury of conspiracy to commit murder in 2008 Groton hotel killing of Jamel Campbell; murder charge retried as mistrial.
- Evidence showed Foley lured Campbell to room 130 at Wright’s direction; police found six spent shell casings from a single gun.
- Car key evidence tied to Strother, Campbell’s girlfriend; threat-related and motive context emerged from Foley’s testimony and records.
- Foley testified to a long-running feud and plans to have Foley lure Campbell to a hotel to enable Wright’s plan to kill him.
- Wright moved to admit third party culpability evidence (Valerie Reinhart) but the court granted the state’s in limine motion and excluded it; defense challenged police investigation quality evidence later.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether third party culpability evidence was correctly excluded | Wright: standard misapplied; Reinhart connected third party to crime. | Wright: evidence directly connects third party to crime; admissible. | Yes, exclusion affirmed; proper standard used and evidence not directly connected. |
| Whether Reinhart's testimony was sufficiently relevant | Reinhart showed third party threat and motive toward victim. | Threat evidence not specific; not directly connecting third party to crime. | No reversible error; no direct connection established; not admissible. |
| Whether the court should have instructed on police investigation quality | Defense theory implied deficient investigation creates reasonable doubt; jury should be charged. | Collins allows consideration but court refused explicit instruction; due process issue. | No error; instructions on reasonable doubt sufficient and defense allowed to argue deficiencies. |
Key Cases Cited
- State v. Cerreta, 260 Conn. 251 (2002) (relevance standard for third party culpability evidence)
- State v. Echols, 203 Conn. 385 (1987) (direct connection requirement for third party evidence)
- State v. Hernandez, 224 Conn. 196 (1992) (motive alone insufficient; requires direct connection)
- State v. Sauris, 227 Conn. 389 (1993) (defendant may introduce third party evidence; must connect directly)
- State v. Boles, 223 Conn. 535 (1992) (relevancy governs admissibility of third party culpability)
- State v. Collins, 299 Conn. 567 (2011) (may consider deficiencies in investigation; not always require charge)
- California v. Trombetta, 467 U.S. 479 (1984) (due process right to present defense; burden on admissibility)
- In re Winship, 397 U.S. 358 (1970) (reasonable doubt standard; due process baseline)
- Jackson v. Virginia, 443 U.S. 307 (1979) (standard for reviewing evidentiary sufficiency)