State v. Eleck, 314 Conn. 123

Defendant charged with first-degree assault with a dangerous instrument (Peacock) and second-degree assault (Finch) after a late-night party in Norwalk where fights occurred.
Defendant allegedly used a knife during the fight and was identified by multiple witnesses as initiating contact with Peacock.
Judway testified for the state; defense sought to impeach her with a Facebook message printout from Simone Danielle.
Defense claimed the printout was authenticated through sua sponte correspondence and Judway’s Facebook profile, but the trial court sustained the state’s authentication objection.
Appellate Court affirmed trial court’s ruling on admissibility of the Facebook printout and held any error harmless, affirming the conviction.
This court granted certification on whether the trial court abused its discretion in not admitting Facebook messages for authentication; court resolves issue on harmless-error grounds.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether excluding Facebook messages was proper authentication failure	Eleck: messages authenticated via defendant’s account and Judway link	Eleck: authentication foundation enough to admit	Harmless error; not substantial impact on verdict
Whether the nonconstitutional evidentiary ruling was harmless	State: strong case; Judway credibility issues minor	Defense: admissible messages would impeach Judway	Harmless error; overall evidence supported conviction

State v. Favoccia, 306 Conn. 770 (Conn. 2012) (harmlessness standard for nonconstitutional evidentiary errors)
State v. Schultz, 100 Conn. App. 709 (Conn. App. 2007) (precedent on appellate review of evidentiary rulings)
Fraley v. Facebook, Inc., 830 F. Supp. 2d 785 (N.D. Cal. 2011) (context of Facebook evidence authentication)
State v. Eleck, 130 Conn. App. 632 (Conn. App. 2011) (procedural posture on admissibility of electronic data)