State v. Gauthier, 140 Conn. App. 69

Defendant assaulted victim in New Britain; victim suffered severe eye injuries and permanent vision loss.
Defendant initially charged with first-degree assault; later information led to continued trial on assault in the second degree.
During trial, defendant sought to dismiss special public defender and proceed with counsel of his choosing or pro se; court denied replacement, then granted standby counsel.
On Nov 2, 2010, defendant sought a continuance to call Light, who would testify to statements by Evans and Haythe; court denied the continuance after determining Light’s testimony was inadmissible.
Court ruled on evidentiary grounds under § 6-10 (c); jury convicted defendant of assault in the second degree; conviction affirmed on appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether denial of continuance violated right to present defense	Light's testimony could impeach witnesses; delay was needed for defense	Denial prevented defense from presenting crucial evidence	No abuse of discretion; denial upheld
Whether Light’s proposed testimony about prior statements was admissible under § 6-10 (c)	Proffered testimony was relevant to credibility and cross-examination	Testimony would be admissible to impeach credibility	Court acted within discretion; testimony inadmissible or noninconsistent
Whether trial court properly applied continuance factors and harmless error analysis	Court’s ruling was based on admissibility and trial efficiency	Court ignored potential prejudice from denial	No reversible error; rulings not abusive; harmless error

State v. Coney, 266 Conn. 787 (2003) (continuance review factors; abuse standard)
Day v. Commissioner of Correction, 118 Conn. App. 130 (2009) (continuance admissibility and evidentiary limits)
State v. Ward, 83 Conn. App. 377 (2004) (foundational requirements for impeachment evidence )
State v. Hines, 243 Conn. 796 (1998) (prior consistent statements generally not admissible)
State v. Saia, 172 Conn. 37 (1976) (discretion to admit impeaching statements without cross-examination)
State v. Whelan, 200 Conn. 743 (1986) (discretion in evaluating inconsistencies between statements)