State v. Henry D., 163 A.3d 642

Victim (12) lived with defendant; alleged sexual assaults occurred in August 2008; disclosure made to family and counselor; video-recorded forensic interview conducted Oct. 7, 2008. Defendant arrested in 2012.
Defendant was charged with sexual assault in the first degree and risk of injury to a child; information later amended to add attempt to commit sexual assault. Jury convicted on attempt and risk of injury but acquitted on sexual assault.
At trial the prosecutor sought to admit the recorded forensic interview as a prior consistent statement to rehabilitate the victim’s credibility after defense cross-examination.
Defense had impeached the victim with apparent inconsistencies between her trial testimony and statements in the interview and questioned whether she had been coached by the prosecutor or her mother.
Court admitted the entire interview (limited purpose: to assess credibility and consistency) and allowed the jury to view the video and follow a transcript.
During rebuttal closing the prosecutor used a jigsaw-puzzle analogy to explain "beyond a reasonable doubt;" defense objected, claiming the analogy diluted the burden. Court overruled; on appeal both issues were raised.

Issue	Plaintiff's Argument (State)	Defendant's Argument	Held
Admissibility of forensic interview as prior consistent statement	Interview was substantially consistent with trial testimony and rebutted suggestion of coaching/undue influence; admissible to aid credibility assessment	Interview contained inconsistencies and thus was hearsay; admission improperly bolstered witness and was not limited to impeached portions	Court held admission proper: prior consistent-statement exception applies where impeachment suggested recent fabrication or coaching; entire interview could be admitted to provide context
Prosecutor’s jigsaw-puzzle analogy in rebuttal	Analogy explained that proof need not be mathematical certainty and responded to defense argument; did not quantify or lower burden	Analogy diluted beyond-a-reasonable-doubt standard and risked conviction on less than required proof	Court held analogy not improper here: prosecutor repeatedly reminded jury state must prove each element beyond a reasonable doubt and did not quantify certainty; analogy permissible in context

State v. Efrain M., 95 Conn. App. 590 (articulating deferential standard of review for evidentiary rulings)
State v. Velez, 17 Conn. App. 186 (prior consistent statements need not be entirely free of inconsistencies)
Daley v. McClintock, 267 Conn. 399 (enumerating exceptions allowing prior consistent statements when impeachment suggests bias, recent fabrication, or undue influence)
State v. Hines, 243 Conn. 796 (admission of entire prior statement to avoid misleading jury and for rehabilitative purposes)
State v. Gordon, 104 Conn. App. 69 (clarifying that jury need not be convinced of every inferred fact beyond a reasonable doubt; only elements must be proved beyond reasonable doubt)