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313 Conn. 325
Conn.
2014
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Background

  • Michelle McMaster was found murdered on March 21, 1999; cause of death was asphyxia by manual strangulation with possible sexual assault.
  • Barry J. Smith was identified as a participant in the basement crime at 17 Burton Street; DNA connected Orenthain Daniel to a vaginal swab; Russell and Reynolds supplied further related testimony.
  • Testimony and evidence showed a group including Smith, Lawrence Andrews, Daniel, and Marvin Slade; Russell described the events in the basement and Readus’s later uncharged misconduct involving choking and sexual assault.
  • Readus testified about an uncharged sexual assault by Smith; the court admitted this evidence under DeJesus to show propensity, identity, and intent with limiting instructions.
  • Readus’s letter alleging a ‘get out of jail free card’ raised a Brady/Napue/Giglio issue; the trial court found no undisclosed agreement and denied relief.
  • The prosecutor exercised a peremptory challenge to remove J.W., an African-American venireperson, which the court found to be race-neutral; Batson claim was rejected.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
admissibility of uncharged sexual misconduct under DeJesus Smith argues insufficient similarity and prejudice Smith contends DeJesus not satisfied and risk of prejudice Court held admissible; not abused discretion; similarities met and prejudice curbed by limiting instruction
Brady claim regarding Readus agreement Readus’s alleged promise was undisclosed; testimony affected trial No undisclosed agreement; statements postdate trial Court upheld denial; no undisclosed agreement; no Brady violation
Batson claim for peremptory challenge of J.W. Prosecutor discriminated based on race by striking J.W. Race-neutral, non-discriminatory reasons supported strike Court upheld Batson ruling; reasons credible; no purposeful discrimination

Key Cases Cited

  • State v. DeJesus, 288 Conn. 470 (2008) (liberal propensity-standard for uncharged sexual misconduct evidence)
  • State v. Snelgrove, 288 Conn. 742 (2008) (admissibility of prior acts and jailhouse informants under DeJesus)
  • State v. Gupta, 297 Conn. 211 (2010) (cross-admissibility of similar misconduct with dissimilar acts)
  • State v. Johnson, 289 Conn. 437 (2008) (similar victims analysis under DeJesus framework)
  • State v. Latour, 276 Conn. 399 (2005) (Batson - factors and deference to trial court findings)
  • Napue v. Illinois, 360 U.S. 264 (1959) (due process requires correction of material false testimony)
  • Giglio v. United States, 405 U.S. 150 (1972) (prosecutorial disclosure of inducements to witnesses needed)
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Case Details

Case Name: State v. Smith
Court Name: Supreme Court of Connecticut
Date Published: Aug 26, 2014
Citations: 313 Conn. 325; 96 A.3d 1238; SC19007
Docket Number: SC19007
Court Abbreviation: Conn.
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