State v. McFarland, SC20802

Background:

In August 1987 Fred and Gregory Harris were found murdered in their Hamden apartment; crime scene included bindings, throat lacerations, a knife in the sink, melted butter, and a yellow work glove.
Willie McFarland had been released from prison the day before the victims were last seen and was arrested nearby early on August 22, 1987 for a separate sexual‑assault incident in which he had been cut and had blood on him.
McFarland gave multiple written and verbal confessions in 1996–97 that variably implicated others but later claimed sole responsibility and accurately described nonpublic crime‑scene details; the state elected not to prosecute then.
Early DNA testing (2009) excluded McFarland from DNA on the glove; advanced touch‑DNA testing in 2018 produced a profile that strongly favored McFarland as a contributor, prompting his 2019 arrest and the 2022 jury trial resulting in convictions.
During the investigation, Veronica Saars‑Doyle gave multiple inconsistent statements implicating third parties; she was deceased at trial and the court excluded her statements under the residual hearsay exception.
On appeal McFarland challenged (1) the 32‑year prearrest delay under federal and Connecticut due process, (2) the court’s refusal to order a further competency evaluation, and (3) exclusion of Saars‑Doyle’s statements; the convictions were affirmed.

Issues:

Issue	Plaintiff's Argument (State)	Defendant's Argument (McFarland)	Held
Prearrest delay — Federal due process	Delay was justified by evolving DNA technology; prosecution began promptly once new evidence existed	32‑year delay caused actual and substantial prejudice and violated due process	Court applied Marion/Lovasco two‑prong test; no violation: no evidence state delayed for tactical/bad‑faith reasons and prejudice claim failed
Prearrest delay — Connecticut due process	Prompt action after DNA developments justified delay; no greater state‑law protection shown	Connecticut constitution affords broader protection; delay requires balancing and here prejudiced defendant	Majority adopted balancing test (threshold prejudice, state explains delay, then court balances); defendant lost on balancing — delay justified
Competency evaluation	No further evaluation necessary; prior evaluations and court observations showed competence	Additional (fifth) evaluation needed because McFarland refused to participate and had delusional beliefs impeding assistance	Trial court did not abuse discretion: four prior evaluations, no substantial change raising reasonable doubt, court properly relied on prior reports and its observations
Admission of Saars‑Doyle statements (residual hearsay)	Statements were unreliable, inconsistent, multilayered hearsay and she was unavailable for cross‑examination	Statements admissible under residual exception as necessary to show third‑party culpability	Court did not abuse discretion in excluding them: statements lacked requisite guarantees of trustworthiness and reliability

Key Cases Cited

United States v. Marion, 404 U.S. 307 (U.S. 1971) (federal due process framework for preindictment delay)
United States v. Lovasco, 431 U.S. 783 (U.S. 1977) (prearrest delay analysis requiring prejudice and improper purpose)
State v. Morrill, 197 Conn. 507 (Conn. 1985) (Connecticut adoption of Marion/Lovasco two‑pronged test)
State v. Carrione, 188 Conn. 681 (Conn. 1982) (earlier Connecticut precedent applying two‑prong test)
State v. Geisler, 222 Conn. 672 (Conn. 1992) (framework for independent state constitutional analysis/balancing)
State v. Bennett, 324 Conn. 744 (Conn. 2017) (residual hearsay exception: narrow, requires necessity plus equivalent guarantees of trustworthiness)
State v. Ross, 269 Conn. 213 (Conn. 2004) (competency: reasonable doubt standard requires substantial evidence; trial court discretion to order evaluations)