State v. Myers, 126 Conn. App. 239

Defendant Michael Myers was convicted at trial of first-degree manslaughter with a firearm, carrying a pistol without a permit, tampering with evidence, and criminal possession of a firearm; total sentence 50 years.
Defendant had a tempestuous relationship with Shaquita Alston, mother of his child; victim was William Corey.
On June 6–7, 2005, Myers accompanied Alston, obtained a handgun, and arranged a meeting with Corey; Myers fired one shot at Corey in Corey's car, killing him.
Trial involved disputed hearsay about Myers' post-shooting statement to a neighbor, with defense seeking admission under spontaneous utterance or residual exceptions.
Court conducted in camera review of Alston’s mental health records; found them largely nonprobative to witness reliability and did not disclose beyond one page already provided.
Photograph of Corey, taken before the offense, was admitted as a full evidentiary exhibit and displayed in enlarged form at closing; defense challenged admissibility and size under statute § 54-85e.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Spontaneous utterance admissibility	Brown testimony supported spontaneous utterance	Statement was spontaneous and reliable	Not admitted; trial court did not abuse discretion
Mental health records disclosure	Records relevant for witness credibility	Defendant entitled to disclosure	Not disclosed beyond one page; no abuse of discretion
Photograph admissibility and display size	Photograph identified victim; statute allows non-evidentiary display	§ 54-85e governs only opening/closing display, not evidentiary exhibit; enlargement prejudicial	Admissible as full exhibit; enlargement not reversible error
Motive instruction to jury	Motive evidence should be described as desirable and important	Instruction misstated the weight of motive evidence	Proper in context; not improper as overall charge balanced
Batson challenge to D's removal	Prosecutor's reasons race-neutral and supported strike	Disparate treatment and pretextual reasons	Batson claim unpreserved for disparate treatment; strike race-neutral reasons upheld

State v. Kendall, 123 Conn.App. 625, 2 A.3d 990 (2010) (excuse as to spontaneous utterance; reliability and immediacy factors)
State v. Peeler, 271 Conn. 338, 857 A.2d 808 (2004) (impeachment and handling of privileged records; in camera procedures)
State v. Faison, 112 Conn.App. 373, 962 A.2d 860 (2009) (residual hearsay admissibility; trustworthiness requirements)
State v. Ervin, 105 Conn.App. 34, 936 A.2d 290 (2007) (photographic evidence admissibility; standard of review)
State v. Bowman, 289 Conn. 809, 960 A.2d 1027 (2008) (photographic evidence prejudice versus probative value; enlargement)
State v. Bardliving, 109 Conn.App. 238, 951 A.2d 615 (2008) (court may weigh probative value against prejudice in photography)
State v. Hodge, 248 Conn. 207, 726 A.2d 531 (1999) (Batson; preservation and review of disparate treatment claims)
State v. Robinson, 237 Conn. 238, 676 A.2d 384 (1996) (timeliness of Batson objections; preservation rule)
State v. Golding, 213 Conn. 233, 567 A.2d 823 (1989) (Golding standard for unpreserved constitutional error)