State v. Crespo, 303 Conn. 589

Crespo was convicted of two counts of first‑degree sexual assault and one count of third‑degree assault based on multiple assaults and sexual assaults against the same victim during a tumultuous relationship.
The victim, initially a virgin with no prior boyfriend, testified that Crespo forcibly penetrated her in December 2002 and later assaulted her on several occasions from 2003 to 2004.
The State sought to admit evidence of the victim's prior sexual conduct under § 54‑86f, but the court limited cross‑examination and barred admission without following the statute's procedures.
The defense offered evidence of the victim's relationship with another man (Anic) to show bias, motive, or deception, arguing it was relevant under § 54‑86f(4).
The trial court and Appellate Court upheld exclusion of that evidence as irrelevant, and Crespo challenged whether the exclusion violated his confrontation and defense rights.
The Supreme Court affirmed the Appellate Court, holding the trial court properly excluded the evidence and that the exclusion did not violate Crespo’s constitutional rights.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether exclusion of prior sexual conduct impeaching evidence violated confrontation and defense rights	Crespo: evidence under § 54‑86f(4) showed bias/motive and credibility undermining the victim.	State: evidence was irrelevant and excluded proper under § 54‑86f; no constitutional violation.	No, exclusion proper; no constitutional violation.
Whether Golding unpreserved claims warrant review given the cross‑examination limitations	Crespo: claim is constitutional; right to confrontation was violated.	State: Golding analysis limits review; evidentiary ruling not clearly constitutional.	Golding review applied; defendant failed to show a clear constitutional violation.

State v. Ritrovato, 280 Conn. 36 (2006) (impeachment evidence under § 54-86f(2) and related admissibility considerations)
State v. Crespo, 114 Conn.App. 346 (2009) (Appellate ruling on admissibility of prior sexual conduct evidence; Golding framework applied)
State v. Golding, 213 Conn. 233 (1989) (establishes Golding test for unpreserved constitutional claims)
State v. Kulmac, 230 Conn. 43 (1994) (confrontation right limits and cross‑examination scope)
State v. Valentine, 255 Conn. 61 (2000) (confrontation rights and cross‑examination standards)