State v. Collins
147 Conn. App. 584
Conn. App. Ct.2014Background
- Collins was convicted at a jury trial of felony murder and robbery in connection with Dixon's March 2009 killing; Dean was involved, having gunfire with Dixon and later pleading guilty to related offenses and being incarcerated when statements at issue were made.
- Dixon carried two cell phones, Cartier glasses, and kept drugs at a safe; the key to the safe was on the same ring as Dixon's car keys; two phones, glasses, and keys were not found at the scene.
- Dean and Collins allegedly conspired in the murder; Dean and Collins met Dixon after Dean arranged to meet with Collins; Dean shot Dixon and then asked Collins to search Dixon's pockets.
- The state introduced written statements Collins gave to Bloomfield police; defense emphasized the circumstances of interrogation and Miranda waiver to challenge reliability.
- The trial court ruled on hearsay and admissibility of certain evidence, including a statement to a prison cellmate and the Cartier glasses found in Dean's home; the court excluded the contested items.
- The defendant appeals, challenging the evidentiary rulings; the court affirms the conviction, upholding the exclusions as proper under the rules of evidence and due process.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility of Dean's cellmate statement | Collins | Dean's statement against penal interest | Excluded as not against penal interest |
| Voluntariness of Miranda waiver evidence | Collins | Need to explore custodial interrogation circumstances | Court did not err; limitations proper to test reliability |
| Admissibility of Cartier glasses found at Dean's home | Collins | Glasses link to Dixon and Dean | Exclusion proper for lack of foundation linking glasses to Dixon |
Key Cases Cited
- State v. Davis, 298 Conn. 1 (2010) (abuse of discretion standard for evidentiary rulings)
- State v. Smith, 289 Conn. 598 (2008) (hearsay and admissibility; testing reliability of statements)
- State v. Snelgrove, 288 Conn. 742 (2008) (standard for upholding trial court rulings; discretion favored)
- State v. Bryant, 202 Conn. 676 (1987) (penal-interest exception requires awareness and self-incrimination risk)
- State v. Pierre, 277 Conn. 42 (2006) (trustworthiness and penal-interest analysis in hearsay)
- Crane v. Kentucky, 476 U.S. 683 (U.S. 1986) (defendant's right to challenge credibility of custodial statement)