State v. Collins
10 A.3d 1005
| Conn. | 2011Background
- Hopkins murder in Bridgeport; shell casing linked to gun used in Rose shooting three months earlier.
- Rose shooting involved defendant possessing the same chrome-and-black nine millimeter handgun; he later confessed to shooting Rose in an interview.
- State sought to introduce Rose shooting evidence at Hopkins trial to prove identity and intent; trial court admitted with limiting instructions.
- Appellate Court reversed, holding admission of Rose shooting evidence was an abuse of discretion and harmful.
- This certified appeal challenges the admissibility ruling, plus two alternative issues: police investigation instruction and defendant’s self-representation canvass.
- We reverse the Appellate Court, affirming the trial court’s balancing and admissibility ruling; also address and reject the alternative grounds.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| admissibility of uncharged misconduct | State contends Rose shooting evidence is probative to identity/intent and admissible. | Collins argues it is highly prejudicial and not necessary to prove any element. | Admission not abuse of discretion; probative value outweighed prejudice. |
| police investigation instruction | Instruction did not mislead; properly limited relevance to defense. | Instruction impermissibly curtailed defense by focusing on guilt beyond investigation. | Instruction does not violate due process; fair to consider the defense within full evidentiary context. |
| canvass for self-representation | Canvass satisfied sixth amendment; waiver valid. | Canvass inadequate to convey sentencing exposure and dangers of self-representation. | Canvass was constitutionally adequate; waiver knowingly, voluntarily, and intelligently made. |
Key Cases Cited
- State v. Randolph, 284 Conn. 328 (2007) (deference to trial court in 4-5 balancing; review for abuse of discretion)
- State v. Beavers, 290 Conn. 386 (2009) (limiting instructions mitigate prejudice; uncharged misconduct framework)
- State v. Dunbar, 51 Conn.App. 313 (1998) (limitations on evidence of prior misconduct)
- State v. Mortoro, 160 Conn. 378 (1971) (prior misconduct evidence scope; cautionary rationale)
- State v. Sharpe, 195 Conn. 651 (1985) (uncharged misconduct admissible to prove certain non-character purposes)
- State v. Diaz, 274 Conn. 818 (2005) (standard for sixth amendment canvass and waivers)
- State v. Williams, 169 Conn. 322 (1975) (relevance of thorough investigation discussion in jury instructions)
