State v. Inglis, 151 Conn.App. 283

Two men were killed and a third wounded in an early February 2008 shooting at a Cromwell nightclub; the defendant was charged with two counts of murder, capital felony, assault in the first degree, and carrying a pistol without a permit.
Eyewitnesses identified Inglis as the shooter; the defense argued Walls, Inglis’s brother, looked alike and may have fired.
The defense sought eyewitness identification instructions and a third party culpability instruction; the court declined both requests.
The court gave standard identification instructions and rejected a third party culpability instruction as a non-typical form; the defendant preserved issues only to a limited extent.
The appellate court affirmed, finding no reversible error in the eyewitness instructions or the third party culpability ruling, and noting Golding review was inapplicable to the misidentification issues.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the court erred by not giving two eyewitness identification instructions	Inglis	Inglis	No reversible error; noncompliance with § 42-18 controls denial; Golding review not applicable
Whether the court erred by declining a third party culpability instruction	Inglis challenged suppression of third party evidence	Court should have charged on third party culpability based on Walls’ resemblance	No; evidence did not establish a direct connection; court acted within discretion
Whether noncompliance with Practice Book § 42-18 barred review	Inglis argues instructional error is reviewable	Rules require separate, cited requests; failure merits denial	Procedural noncompliance supports denial of this relief
Whether Golding review applied to the unpreserved claim about cornrows identification	Inglis urges Golding review for constitutional claim	Claim not constitutional and not preserved	Golding review did not apply; claim not constitutional

State v. Corbin, 260 Conn. 730 (2002) (practice-note on §42-18 cooperation and form of requests)
State v. Golding, 213 Conn. 233 (1989) (constitutional claims require elements of offense, burden, or innocence)
State v. Cerilli, 222 Conn. 556 (1992) (identification instructions are not constitutional per se)
State v. Tillman, 220 Conn. 487 (1991) (misidentification instructions are nonconstitutional error)
State v. Arroyo, 284 Conn. 597 (2007) (third party culpability requires a direct connection with the crime)
State v. Jackson, 304 Conn. 383 (2012) (abuse of discretion standard for third party culpability rulings)
State v. Small, 242 Conn. 93 (1997) (defendant entitled to theory of defense instruction for legally recognized defenses)
State v. Rosado, 178 Conn. 704 (1979) (denial of third party culpability instruction not automatically reversible)
State v. Golodner, 305 Conn. 330 (2012) (defense not entitled to instruction for non-recognized defenses)
State v. Echols, 203 Conn. 385 (1987) (instructional guidance on third party culpability)
State v. Canales, 281 Conn. 572 (2007) (procedural preservation requirements govern review)
State v. Fourtin, 307 Conn. 186 (2012) (appellate limits on reviewing unpreserved claims)