State v. Grant, 178 A.3d 437

Defendant, David Grant, was convicted after a jury trial of manslaughter in the first degree with a firearm and assault in the first degree; one count of murder was acquitted.
Shooting occurred at the Mai Thai restaurant in Norwich around 1:40 a.m. on June 24, 2012, injuring two patrons and resulting in death of Donna Richardson.
Forensic evidence linked the recovered firearm to bullets in the victims; DNA on the firearm implicated the defendant; a digital video of a police interview was admitted.
Velez testified that Grant sold drugs and carried a firearm prior to the night of the shooting; the state sought to introduce prior misconduct through Velez.
Grant challenged two evidentiary rulings: admission of drug-sale evidence and redirect examination about prior firearm observations; the trial court issued limiting instructions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether admission of drug-sale evidence was improper	Grant	Grant	Harmless error; strong corroborating evidence supports verdict
Whether redirect testimony about prior firearm observations was improper	Grant	Grant	Harmless error; other evidence independently established guilt

State v. Rodriguez, 311 Conn. 80, 83 A.3d 595 (2014) (Conn. (2014)) (harmlessness factors guide evidentiary rulings)
State v. Bouknight, 323 Conn. 620, 149 A.3d 975 (2016) (Conn. (2016)) (multiple eyewitnesses and corroborating evidence render error harmless)
State v. Bonner, 290 Conn. 468, 964 A.2d 73 (2009) (Conn. (2009)) (unindicted misconduct evidence harmless with corroboration)
State v. Cutler, 293 Conn. 303, 977 A.2d 209 (2009) (Conn. (2009)) (instructional safeguards minimize prejudice from prior misconduct evidence)
State v. Payne, 303 Conn. 538, 34 A.3d 370 (2012) (Conn. (2012)) (harmless-error analysis for redirect evidentiary rulings)