State v. Clark, 314 Conn. 511

Clark attacked victim Hauter at Evey’s Sports Café, striking her with a beer bottle and causing serious injuries; the state sought to impeach Clark with five prior felonies; the trial court allowed impeachment using four older felonies; Appellate Court found the admission of those four convictions was an abuse of discretion but harmless; the jury acquitted on one theory of first-degree assault and convicted on the other; Supreme Court affirmed the Appellate Court’s judgment without further discussion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the admission of four prior felonies harmless error?	State argues admissibility under §6-7(a) balancing; error harmless.	Clark contends the convictions were unfairly prejudicial and not probative.	Harmless error; no substantial prejudice to verdict.
Did the Appellate Court properly apply §6-7(a) remoteness and prejudice factors?	State asserts proper balancing under the three-factor test.	Clark argues improper weighting and remoteness analysis.	Appellate Court properly applied three-factor balancing and Sawyer fair-assurance standard.

Label Systems Corp. v. Aghamohammadi, 270 Conn. 291 (2004) (established approach to remoteness under § 6-7(a) distinct from Fed. Rule 609(b))
State v. Sawyer, 279 Conn. 331 (2006) (nonconstitutional error harmless if fair assurance verdict not substantially affected)
State v. Whelan, 200 Conn. 753 (1986) (admission of statements as substantive evidence under State v. Whelan)
State v. Clark, 137 Conn. App. 203 (2012) (Appellate Court’s analysis of impeachment and remoteness prior to Supreme Court review)
State v. Clark, 307 Conn. 915 (2012) (Supreme Court certification decision and discussion of similar issues)