State v. Myers, 352 Conn. 770

Cornel Myers was convicted of murder for killing his former girlfriend after she ended their relationship.
Myers sought to introduce third-party culpability evidence implicating the victim's neighbor, Adduci, but the trial court excluded some of this evidence.
The excluded evidence involved Adduci's video messages, a voicemail, his prior alleged violent acts, and his deteriorating mental health after the murder.
The defendant argued that the exclusion of this evidence violated his constitutional rights and hindered his ability to present a full defense.
There was strong forensic and circumstantial evidence implicating Myers, including DNA, handwritten notes at the scene, and extensive unwanted contact with the victim prior to her death.
Myers also argued the prosecutor improperly shifted the burden of proof during trial, but the trial court issued curative instructions and declined to declare a mistrial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Exclusion of third-party culpability evidence	Abuse of discretion; violated right to full defense	Not central to defense; exclusion did not deprive of fair trial	Any error was evidentiary, not constitutional; exclusion was harmless
Constitutional violation from evidentiary ruling	Prevented presenting strong evidence of third-party guilt	Admitted evidence was sufficient for defense to present its theory	No violation since substantial evidence supporting defense was presented
Harmlessness of evidentiary errors	Excluded evidence was crucial to defense	Most important third-party evidence was admitted;	Error, if any, was harmless given strength of state's case and available evidence
Burden of proof in prosecutor's questioning	Prosecutor improperly shifted burden, causing unfair trial	Prosecutor did not say defense had obligation; court issued instructions	No abuse of discretion in denying mistrial; curative instructions remedied any error

State v. Hedge, 297 Conn. 621 (2010) (threshold for admissibility of third-party culpability evidence)
State v. Jordan, 329 Conn. 272 (2018) (constitutional error requires exclusion to preclude all evidence of the theory)
State v. Osimanti, 299 Conn. 1 (2010) (distinguishes constitutional from evidentiary errors in exclusion cases)
State v. Devalda, 306 Conn. 494 (2012) (centrality of excluded evidence to defense)
State v. West, 274 Conn. 605 (2005) (right to present defense based on centrality and quantum of other evidence)