State v. Kehayias, 162 Conn.App. 310

Defendant Demetrios Kehayias convicted after a bench trial of disorderly conduct, risk of injury to a child, criminal violation of a protective order, and first‑degree reckless endangerment arising from two incidents (Feb 26 and July 21, 2011).
Feb 26 incident: at a custodial exchange defendant insulted and gestured a gun at the mother (K) while holding their one‑year‑old son (L); K recorded portions and disorderly conduct charge followed.
July 21 incident: on I‑84 K and her mother (M) alleged a Jeep driven by defendant cut in front of K, braked, causing K to swerve; K and M identified defendant as driver; the defendant later admitted to a trooper he had cut off and braked in front of a car.
Defendant waived a jury, was convicted on all counts, and appealed arguing (1) insufficiency of evidence as to the July 21 charges (identity and intent) and (2) violation of his Sixth Amendment right to confront/impeach K by (a) exclusion of a question about a March 14 family court event and (b) exclusion of a videotape.
Trial court credited K’s and M’s identifications and found defendant not credible; appellate court reviews sufficiency by construing evidence in prosecution’s favor and defers to factfinder on credibility.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for July 21 highway offenses (identity/general intent)	State: K and M’s eyewitness ID plus defendant’s admission to trooper sufficiently prove identity and the acts required for risk of injury, violation of protective order, and reckless endangerment	Kehayias: IDs unreliable (hat/sunglasses, stress, bias) and no proof he knew K’s whereabouts for protective‑order intent	Affirmed: eyewitness IDs and defendant’s admission viewed favorably support convictions; credibility determinations upheld
Sixth Amendment right to confront/impeach (cross‑examination about March 14 family court and exclusion of videotape)	State: court properly limited irrelevant or duplicative inquiry; K’s bias was extensively developed on cross	Kehayias: exclusion of the family‑court question and the video curtailed ability to show motive to fabricate and thus violated confrontation/presentation rights	Affirmed: limits were permissible; inquiry into K’s motive was already robustly developed and exclusion was an isolated ruling, not a constitutional violation

State v. Michael H., 291 Conn. 754 (2009) (standard for sufficiency review)
State v. Morgan, 274 Conn. 790 (2005) (sufficiency standard; credibility deference)
State v. Osoria, 86 Conn. App. 507 (2004) (credibility and appellate review limitations)
United States v. Wade, 388 U.S. 218 (1967) (factors for eyewitness identification reliability)
State v. Milum, 197 Conn. 602 (1985) (confrontation error where motive/bias wholly concealed)
State v. Lubesky, 195 Conn. 475 (1985) (limited exclusion of a single impeachment question may be harmless where bias otherwise exposed)
State v. Baltas, 311 Conn. 786 (2014) (preclusion of motive inquiry can violate confrontation clause)