State v. Coccomo, 31 A.3d 1012

Defendant Tricia Coccomo was convicted by a jury of three counts of second-degree manslaughter with a motor vehicle, three counts of misconduct with a motor vehicle, and one count of operating under the influence, following a fatal collision.
Evidence admitted at trial included a postaccident transfer of Coccomo's one-half interest in a Stamford residence to her mother for $1 and other <$100 value, offered to prove consciousness of guilt.
The State also introduced blood alcohol test results showing BAC around 0.241 at the time of the collision, prompted by Coccomo's earlier statements and conduct.
The Appellate Court reversed, holding the property-transfer evidence was an abuse of discretion and violated due process by inflaming the jury, while addressing other issues related to the blood alcohol evidence.
The State petitioned for certification to appeal, limited to whether the trial court abused its discretion by admitting the property-transfer evidence for consciousness of guilt.
The Supreme Court, with majority decision, held the trial court did not abuse its discretion regarding the property-transfer evidence and rejected Coccomo's plain-error challenge to the blood test results.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the transfer of property for less than fair value was admissible as consciousness of guilt	State argues probative because it shows guilty conscience	Coccomo argues it is ambiguous and overly prejudicial	Admissible; not an abuse of discretion
Whether admitting the blood alcohol test results was plain error	State maintains results were admissible and reliable	Coccomo contends chain of custody flaws and misattribution of blood	Not plain error; no reversal on plain-error grounds

State v. DePastino, 228 Conn. 552 (1994) (consciousness of guilt evidence may be admitted if probative and not chilling rights)
State v. Freeney, 228 Conn. 582 (1994) (ambiguity alone does not bar consciousness of guilt evidence; consider probative value and policy constraints)
State v. Kelly, 256 Conn. 23 (2001) (jury may draw inferences from consciousness of guilt; not required to exclude all innocent explanations)
Batick v. Seymour, 186 Conn. 632 (1982) (civil context; post-accident transfers may be admissible but higher stigmatic risk in criminal trials)
State v. Camacho, 92 Conn.App. 271 (2005) (consciousness of guilt evidence and balancing test under 4-3 of the Code of Evidence)