State v. Raynor, 181 Conn. App. 760

Defendant Donald Raynor was tried and convicted of murder for a 2007 drive‑by shooting that killed the victim; co‑defendant Jose Rivera implicated Raynor and identified a seized .223 Kel‑Tec rifle as the murder weapon.
Twelve of fifteen cartridge casings from the murder scene were positively matched by the state’s firearm/toolmark expert to the .223 Kel‑Tec; three were inconclusive.
Defense sought a Porter hearing and moved in limine to exclude or limit the state expert’s firearm/toolmark testimony, citing reports (NAS, Ballistic Imaging) and case law questioning the scientific reliability of firearm/toolmark identification.
Trial court denied the Porter hearing and admitted the expert’s identification testimony; the expert acknowledged some criticisms during cross‑examination.
State also moved to admit uncharged misconduct evidence of an attempted shooting eight months later (Baltimore St. incident) in which casings from that scene were largely matched to the same .223 rifle; the court admitted that evidence to prove identity and means and gave limiting instructions.
On appeal, Raynor argued (1) the court should have held a Porter hearing and excluded/limited the ballistics testimony, and (2) the uncharged‑misconduct evidence was more prejudicial than probative. The conviction was affirmed.

Issue	State's Argument	Raynor's Argument	Held
Whether a Porter (Porter v. State) reliability hearing was required before admitting firearm/toolmark identification evidence	Ballistics/toolmark identification is long‑established forensic science; relevance suffices and prior Connecticut precedent allows admission without Porter hearing	Recent studies and out‑of‑state decisions cast doubt on the methodology’s reliability; expert testimony should be excluded or limited to "more likely than not" conclusions	Denied Porter hearing; court followed controlling precedent (State v. Legnani) and admitted expert testimony; cross‑examination exposed limitations for the jury to weigh
Whether admission of uncharged misconduct (Baltimore St. attempted shooting) was unduly prejudicial	Evidence was relevant to identity and means (same rifle linked to both incidents); probative value outweighed prejudice; limiting instructions mitigate prejudice	Evidence unduly prejudicial, risks propensity inference, unreliable eyewitness ID, and paints defendant as a "deranged gunman"	Admission upheld: charged conduct was more severe, similarities were probative (same gun/person), limiting instructions given, and trial court did not abuse discretion

State v. Porter, 241 Conn. 57 (Conn. 1997) (established Connecticut’s flexible test for admissibility of scientific evidence).
State v. Legnani, 109 Conn. App. 399 (Conn. App. 2008) (held firearm/toolmark identification is well‑established forensic science; Porter hearing not required for such evidence).
State v. Collins, 299 Conn. 567 (Conn. 2011) (described admissibility and balancing test for uncharged‑misconduct evidence and the factors for weighing prejudice vs. probative value).
United States v. Glynn, 578 F. Supp. 2d 567 (S.D.N.Y. 2008) (recognized limitations in ballistics testimony and limited expert’s opinion to "more likely than not").