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State v. Collins
10 A.3d 1005
| Conn. | 2011
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Background

  • 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)
Read the full case

Case Details

Case Name: State v. Collins
Court Name: Supreme Court of Connecticut
Date Published: Jan 5, 2011
Citation: 10 A.3d 1005
Docket Number: SC 18297
Court Abbreviation: Conn.