132 Conn. App. 550
Conn. App. Ct.2011Background
- The August 7, 2009 stabbing of Devore Anderson occurred in Bridgeport; two fights with Miles preceded the stabbing.
- Anderson and her sister Porter identified Miles as the assailant; Porter described the assailant’s build and dreadlocks and identified Miles from a photographic array.
- Miles sought to introduce evidence that Anderson had been stabbed years earlier by an unidentified third party; the trial court excluded it as irrelevant.
- Miles argued the exclusion violated due process and her right to present a defense; she invoked Golding for constitutional claims.
- The court ruled the proffer lacked a direct connection to the charged crime, so the evidence was not relevant and properly excluded.
- The jury heard testimony from two witnesses identifying Miles as the stabber; no forensic DNA evidence was required to prove identity.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the trial court properly excluded third-party culpability evidence. | Miles argued the prior stabbing showed a possible third party. | The court correctly found no direct connection to Miles. | Exclusion was proper due to lack of relevancy. |
| Whether forensic evidence was necessary to prove identity. | DNA from the scene should have been tested to prove identity. | Identification by two witnesses suffices without DNA. | Forensic evidence not required when two witnesses identify the defendant. |
| Whether the evidence was sufficient to establish Miles as the perpetrator. | Credibility disputes over identification undermine sufficiency. | Credibility lies with the jury; testimony supports identity beyond reasonable doubt. | Evidence sufficient to identify Miles as the perpetrator. |
Key Cases Cited
- State v. West, 274 Conn. 605 (2005) (requires direct connection for third-party culpability evidence)
- State v. Cerreta, 260 Conn. 251 (2002) (exculpatory evidence may be admissible even if not third-party culpability)
- State v. Eagles, 74 Conn. App. 332 (2002) (credibility determinations left to jury; misidentification concerns)
- State v. Arroyo, 284 Conn. 597 (2007) (proffer must show direct connection to third party)
- State v. West, 274 Conn. 624 (2005) (reiterates relevancy standard for third-party culpability)
- State v. Smith, 280 Conn. 285 (2006) (identification testimony can suffice without forensic corroboration)
- Jackson v. Virginia, 443 U.S. 307 (1979) (standard for sufficiency of evidence to convict)