193 Conn.App. 285
Conn. App. Ct.2019Background
- Victim Shamari Jenkins, four months pregnant with Carlton Bryan’s child, refused Bryan’s requests for an abortion; Bryan recruited Matthew Allen Hall‑Davis to kill her.
- On April 29, 2013 Hall‑Davis fatally shot the victim through the rear windshield while she and Bryan were in her parked car; Bryan initially told police an unknown robber shot her.
- Hall‑Davis later told friend Kingsley Minto that he had killed the victim at Bryan’s behest; Hall‑Davis and Minto then used the same .44 Ruger in a subsequent robbery and hid the gun.
- At trial Hall‑Davis invoked the Fifth Amendment and was unavailable; Minto testified to Hall‑Davis’s statements. The trial court admitted those statements under Conn. Code Evid. § 8‑6(4) as dual inculpatory (statement against penal interest).
- Bryan was convicted of murder and conspiracy; he also claimed the state violated Brady by failing to disclose Hartford PD internal affairs files (2005 and 2008) concerning Detective Reginald Early, who investigated the case.
- The trial court placed the internal affairs records in the appellate record but denied a Floyd hearing; the appellate court affirmed the convictions.
Issues
| Issue | State's Argument | Bryan's Argument | Held |
|---|---|---|---|
| Admissibility of Hall‑Davis’s out‑of‑court statements under Conn. Code Evid. § 8‑6(4) (dual inculpatory / statement against penal interest) | Statements were self‑inculpatory, implicated Hall‑Davis and Bryan equally, and bore indicia of trustworthiness (timing, close relationship with Minto, corroboration). | Portions shifted blame to Bryan and were not fully against Hall‑Davis’s penal interest; statements lacked sufficient trustworthiness. | Affirmed admission: entire statements were against Hall‑Davis’s penal interest and sufficiently trustworthy (timely, to a close friend, corroborated). |
| Alleged Brady nondisclosure of 2005 and 2008 internal affairs files about Det. Early | Files were not material; impeachment value would be cumulative and would not undermine confidence in the verdict given overwhelming corroborating evidence. | Nondisclosure deprived Bryan of impeachment material that could undercut Early and thereby the cooperating witnesses (Minto, Walker); entitles him to new trial / Floyd hearing. | No Brady violation: records not material to guilt; impeachment would not create reasonable probability of different result; no relief. |
Key Cases Cited
- Brady v. Maryland, 373 U.S. 83 (1963) (prosecution must disclose favorable, material evidence to avoid due‑process violation)
- United States v. Bagley, 473 U.S. 667 (1985) (Brady materiality standard: reasonable probability of different result)
- State v. Golding, 213 Conn. 233 (1989) (standard for appellate review of unpreserved constitutional claims)
- State v. Pierre, 277 Conn. 42 (2006) (factors and discretion in assessing trustworthiness of statements against penal interest)
- State v. Camacho, 282 Conn. 328 (2007) (dual inculpatory statements analyzed by exposure of declarant to same liability as defendant)
- State v. Rivera, 268 Conn. 351 (2004) (statement against penal interest and treatment of apparent blame‑shifting)