State v. Sampson, 166 A.3d 1

On June 10, 2012 Hartford officers pursued a Toyota Camry (Driver: D’Amico Sampson; Passenger: Tyran Sampson) after radioed reports and an earlier near-collision with an East Hartford sergeant; stop sticks disabled the vehicle.
The driver fled on foot; Tyran (defendant) remained in the passenger seat and did not obey officers’ orders to exit.
Officer Pia pulled the defendant from the car after a physical struggle in which the defendant kicked Pia and attempted to take his gun; officers then subdued and handcuffed the defendant.
Defendant was charged with assault of public safety personnel and failure to appear; trial on the assault charge resulted in conviction of the lesser included offense, interfering with an officer (§ 53a-167a).
At trial the state moved in limine to exclude (a) prior internal counseling received by Officer Ortiz regarding report-writing and (b) certain testimony from East Hartford officers about the Family Dollar robbery investigation, radio dispatches, and charges against the driver; the court granted those exclusions.
On appeal defendant argued the exclusions violated (1) his Sixth Amendment Confrontation right (impeachment of Ortiz) and (2) his right to present a defense (evidence showing officers acted unreasonably / outside their duties); the appellate court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Exclusion of Ortiz's prior counseling as impeachment	State: counseling related to report-writing, not veracity, therefore irrelevant and properly excluded	Sampson: counseling showed Ortiz’s report-writing deficiencies and could impeach her testimony about whether he kicked Pia	Exclusion not an abuse of discretion; counseling concerned report detail/training, not propensity to lie, so not probative of veracity or of whether defendant kicked Pia
Exclusion of East Hartford officers' testimony (investigation details, radio dispatches, driver charges)	State: details collateral, hearsay or irrelevant to elements of charged offense; essential facts about pursuit were admitted	Sampson: evidence showed officers acted unreasonably/with mistaken dangerousness (e.g., suspect heights, robbery suspicion), so Pia lacked authority and force was unreasonable	Court did not abuse discretion; testimony was collateral or not shown to have affected Pia (no proof Pia heard those dispatches), and core defense—reasonableness of force—was presented to jury

State v. Reeves, 57 Conn. App. 337 (2000) (Confrontation Clause permits effective but not unlimited cross-examination; trial court controls relevancy)
State v. Annulli, 309 Conn. 482 (2013) (abuse-of-discretion standard for evidentiary rulings and confrontation analysis)
State v. West, 274 Conn. 605 (2005) (defendant’s right to present a complete defense balanced against evidentiary rules)
State v. Zillo, 124 Conn. App. 690 (2010) (relevance = probative value and materiality under Conn. Code of Evidence)
State v. Gonzalez, 272 Conn. 515 (2005) (broad trial court discretion on admissibility; reversal only for manifest abuse)
State v. Golding, 213 Conn. 233 (1989) (standard for unpreserved constitutional claims review)
Dinan v. Marchand, 279 Conn. 558 (2006) (statements offered for their effect on the listener are not hearsay)
Barros v. Barros, 309 Conn. 499 (2013) (procedural note on state constitutional analysis when not separately briefed)
State v. Geisler, 222 Conn. 672 (1992) (framework for state constitutional claims)