State v. Sanchez, 146 A.3d 344

In October 2010, Luis Sanchez retrieved a handgun from a car after leaving a bar and fired two volleys (12 shots total) into a crowd; Jeanna Flores was killed and two others were wounded. Sanchez later admitted firing but claimed defense of others at trial.
After the shooting Sanchez and companions fled, fabricated an alibi, attempted to have a witness corroborate it, and disposed of the gun in a river. He was later identified by surveillance video and other witnesses.
The state sought to admit evidence of a June 2009 shooting in which a victim (Fred Colby) identified Sanchez as one of two shooters and police ballistics matched a 9mm casing from that incident to casings in the 2010 shooting. The state offered the prior act to prove intent and to show access to the weapon (identity).
The trial court admitted the 2009-incident evidence; the jury heard testimony on ballistics and the earlier shooting and received limiting instructions that the evidence could be considered for intent and for access to the instrumentality (the gun), but not propensity.
Sanchez testified and for the first time claimed he shot to protect friends; the prosecutor played a recording showing an investigator had suggested the self-defense theory to Sanchez previously. The jury convicted Sanchez of murder and two first-degree assaults and the court sentenced him to an effective 65-year term.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Sanchez)	Held
Admissibility of 2009 prior-misconduct evidence to prove intent	Evidence is admissible to prove intent and identity/access to the weapon; ballistics link makes it probative	Prior act too remote and unrelated; high prejudicial propensity inference; irrelevant to 2010 mental state	Even assuming admission for intent was erroneous, any error was harmless because evidence was properly admitted on unchallenged ground (access/identity) and the remaining record strongly supported intent and rebutted defense of others
Jury instruction permitting use of 2009 act to show intent	Limiting instructions appropriately explained narrow uses (intent and access)	Any instruction allowing use for intent was confusing and necessarily led jurors to improper propensity inferences; harmful in light of intent being the central contested issue	Any instructional error was harmless given overwhelming circumstantial evidence of intent and factors undermining the self-defense claim

State v. Merriam, 264 Conn. 617 (recognizes exceptions to bar on prior misconduct evidence and two-part admissibility test)
State v. Jacobson, 283 Conn. 618 (framework for harmlessness review of nonconstitutional evidentiary error)
State v. O’Bryan, 318 Conn. 621 (explains subjective-objective test for belief in necessity of deadly force in self-defense/defense-of-others)
State v. Otto, 305 Conn. 51 (circumstantial evidence and manner of use of weapon probative of intent to kill)
State v. Raguseo, 225 Conn. 114 (carrying or possessing a deadly weapon prior to offense can support inference of intent)
State v. Saunders, 267 Conn. 363 (calm demeanor and absence of recovered weapon undermine claim of reasonable fear and self-defense)