State v. Best, 337 Conn. 312

On May 4, 2006 Durante D. Best shot Octavia Anderson and Rogerlyna Jones in the chest after they demanded he open a locked bedroom door; both women fled to Octavia’s car and drove to the hospital. Jones died; Octavia survived.
Octavia’s Dodge Stratus interior was photographed showing blood on seats, console, cup holder and footwell; four such interior photographs were offered by the state and admitted as full exhibits over Best’s objection.
Best testified he shot either accidentally or in self-defense; the state needed to prove causation, that Jones’s death and Octavia’s injuries were grievous (serious physical injury), and specific intent to kill or to cause serious injury.
At trial the defense objected that the car photographs were irrelevant and unduly prejudicial; the trial court admitted them; Best was convicted and appealed the evidentiary ruling.
The Connecticut Supreme Court reviewed whether the photographs were relevant (tendency to prove severity/causation, intent, and corroboration) and whether their probative value was outweighed by undue prejudice.

Issue	State's Argument	Best's Argument	Held
Relevance of car‑interior photographs	Photos tend to prove severity of wounds, corroborate Octavia, and are probative of causation and intent	Photos were not probative (not crime‑scene/autopsy/wound photos) and therefore irrelevant	Relevant: photos tended to show blood loss severity, corroborated testimony, and bore on causation and intent; Best preserved relevance claim
Prejudicial effect vs. probative value (Conn. Code Evid. §4‑3)	Photos were not unusually graphic relative to the other evidence and their probative value outweighed any prejudice	Bloody imagery was inflammatory and likely to improperly inflame jurors	No abuse of discretion: trial court reasonably concluded probative value outweighed risk of unfair prejudice; broad deference to trial court decision

State v. Wilson, 64 A.3d 91 (Conn. 2013) (definition and standard for relevant evidence)
State v. Kelly, 770 A.2d 908 (Conn. 2001) (photographs admissible when they tend to prove or disprove a material fact)
State v. DeJesus, 481 A.2d 1277 (Conn. 1984) (wound photographs relevant to cause and manner of death)
State v. Doehrer, 513 A.2d 58 (Conn. 1986) (photograph of injuries admissible to corroborate testimony and prove intent)
State v. Jacobson, 930 A.2d 628 (Conn. 2007) (test for undue prejudice: whether evidence improperly arouses jurors’ emotions)
State v. Satchwell, 710 A.2d 1348 (Conn. 1998) (trial court has broad discretion in balancing probative value against prejudice)
State v. Epps, 936 A.2d 701 (Conn. App. 2007) (seriousness of injuries relevant to proving intent to kill or to cause serious injury)