State v. James K., 347 Conn. 648

Victim (V) lived with defendant (her father) from about age six to twelve; defendant frequently used physical discipline and once touched V’s intimate parts in her bedroom (no penetration).
After the defendant’s 2015 arrest on unrelated charges, V disclosed abuse during a Department of Children and Families investigation and a 2016 forensic interview was video‑recorded.
During jury selection the prosecutor said she might introduce photos of the defendant kissing the half‑sister (H) on the lips; defense counsel sought to ask venirepersons about views on parents kissing children on the lips. The trial court barred that specific question but allowed broader questions about parental affection and later excluded the photo(s) as unduly prejudicial.
Defense moved in limine to exclude the forensic interview video as cumulative and unduly prejudicial; after V testified the court admitted the video under the medical diagnosis/treatment hearsay exception.
The Appellate Court affirmed the conviction for risk of injury to a child; the Supreme Court granted certification and (1) clarified the standard for voir dire restriction challenges and (2) affirmed admission of the forensic interview video, while noting redaction is an available tool to limit prejudice.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Trial court’s restriction on defense voir dire (asking venire about parents kissing children on the lips)	The court’s limitation was within its wide discretion to avoid fact‑specific conditioning of jurors	The restriction prevented meaningful probing of potential bias about a piece of evidence likely before the jury, causing harmful prejudice	Even assuming a clear abuse of discretion, defendant failed to show harmful prejudice; reversal requires both clear abuse and harmful prejudice (conjunctive test)
Admissibility of video‑recorded forensic interview (probative v. prejudicial)	The video was probative: contained details not elicited at trial and fit the medical diagnosis/treatment exception; the court considered prejudice and probative value	The video was cumulative, improperly bolstered V’s credibility, and its prejudicial effect outweighed probative value	The trial court did not abuse its discretion: the video was probative and not unduly prejudicial; courts and parties should consider targeted redaction to limit prejudice

State v. Dahlgren, 200 Conn. 586 (1986) (trial court has wide discretion in conducting voir dire)
Childs v. Blesso, 158 Conn. 389 (1969) (articulated disjunctive formulation that caused later confusion)
State v. Lee, 69 Conn. 186 (1897) (early articulation of wide discretion in voir dire and harm requirement)
Sherman v. William M. Ryan & Sons, Inc., 126 Conn. 574 (1940) (voir dire scope rests largely in trial court discretion)
State v. Fritz, 204 Conn. 156 (1987) (harmless error analysis applied to voir dire restriction)
State v. Nunes, 260 Conn. 649 (2002) (no requirement of on‑the‑record balancing if record permits inference that court considered prejudice)
State v. Roy D. L., 339 Conn. 820 (2021) (encourages consideration of redaction of forensic interviews)
State v. Sandoval, 263 Conn. 524 (2003) (standard for unfair prejudice under evidentiary balancing)
State v. Gray, 342 Conn. 657 (2022) (caution on excluding evidence solely because it overlaps existing testimony)