State v. Benedict, 136 Conn. App. 36

Benedict convicted at trial of one count of sexual assault in the fourth degree against a 17-year-old complainant who was a high school student; the conduct occurred in Benedict's capacity as a teacher and coach.
Complainant later reported the incident to state police; Benedict was charged with three counts of sexual assault in the fourth degree, two for the complainant and one for another student.
Complainant had a pending felony drug charge and entered a pretrial diversion program with potential dismissal upon successful completion.
Defense sought to cross-examine the complainant about the pending felony and the diversion program; the court initially refused but allowed later limited questioning.
Prosecution redirected on the diversion program details, prompting defense to seek further cross-examination about other probation conditions; the court constrained this inquiry.
Court reversed, finding a Sixth Amendment confrontation clause error requiring reversal for a new trial; question of admissibility of a login-identification used as character evidence was remanded for retrial consideration.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether restricting cross-examination violated confrontation rights	Benedict argues the door was opened to question pending charge to expose motive	State argued cross-exam should be limited to ensure credibility and avoid prejudice	Reversed for error; confrontation rights violated
Whether allowing login-identification as character evidence was proper	State properly admitted as probative of defendant's character related to not having sexual contact with students	Login evidence constituted impermissible general bad character evidence not tied to permissible trait	Remanded; admission deemed abuse of discretion

State v. Castro, 196 Conn. 421 (1985) (two-step analysis of cross-examination and sixth amendment)
Davis v. Alaska, 415 U.S. 308 (1974) (right to cross-examine for bias and motive against adverse witness)
State v. Milner, 206 Conn. 512 (1988) (confrontation rights do not automatically bar reversal; state must show harmlessness)
State v. Cohane, 193 Conn. 474 (1984) (harmless error standard for confrontation clause violations)
State v. Ouellette, 190 Conn. 84 (1983) (limits on cross-examination where credibility affected)
State v. Johnson, 21 Conn.App. 291 (1990) (precludes all inquiry into witness bias; limits on cross-examination)
State v. Ortiz, 198 Conn. 220 (1985) (witness's interest or bias as admissible in cross-examination)
State v. Lubesky, 195 Conn. 475 (1985) (pendency of charges can influence testimony)
State v. Camerone, 8 Conn.App. 317 (1986) (plea agreements and evidence of witness cooperation)
State v. Reed, 56 Conn.App. 428 (2000) (pendency of criminal charges affects credibility of witness)
State v. Martin, 170 Conn. 161 (1976) (limits on cross-exam to matters relevant to charged element)