351 Conn. 324
Conn.2025Background
- Brandon Jones was convicted of murder in connection with the 2005 shooting death of Dante Davis in Hartford, Connecticut.
- The prosecution argued the shooting was motivated by an ongoing feud between two street gangs, "The Ave" (with which Jones was allegedly affiliated) and "West Hell."
- Evidence linking Jones to the gang and indicating motive came from multiple police and witness testimonies about the group affiliations and the context of neighborhood violence.
- After more than 16 years without charges, Jones was arrested in Texas following tips from two incarcerated witnesses.
- Jones appealed his conviction, arguing the trial court erred by admitting evidence of his alleged gang affiliation and his actions after law enforcement attempted to arrest him in Louisiana, claiming prejudice and lack of relevance.
Issues
| Issue | Appellant's Argument | State's Argument | Held |
|---|---|---|---|
| Admission of gang affiliation evidence | Jones: Irrelevant and highly prejudicial; no established link to the crime | State: Relevant to establish motive; linked feud explains shooting | Properly admitted; probative outweighs prejudice |
| Admission of post-arrest attempt conduct (consciousness of guilt) | Jones: Conduct too remote from crime; not indicative of guilt | State: Evasive conduct occurred right after learning of warrant; shows guilt | Properly admitted as probative evidence |
Key Cases Cited
- State v. Bermudez, 341 Conn. 233 (evidence of gang affiliation is admissible to show motive or bias if its probative value outweighs prejudicial risk)
- State v. Wilson, 308 Conn. 412 (gang evidence properly admitted to establish motive for killing)
- State v. Taylor, 239 Conn. 481 (gang evidence used to establish motive and permissible with proper limiting instruction)
- State v. Hill, 307 Conn. 689 (consciousness of guilt evidence is admissible if relevant and more probative than prejudicial)
- State v. Oliveras, 210 Conn. 751 (flight and evasive action are classic forms of consciousness of guilt evidence)
