State v. Solomon, 150 Conn.App. 458

Defendant Solomon shot at Robert Johnson in Hartford on Aug 28, 2010, using a silver revolver; Johnson identified the weapon and defendant at close range.
Defendant faced four charges including attempt to commit murder, attempt to commit first-degree assault, carrying a revolver without a permit, and criminal possession of a firearm, with the firearm count tried to the court after a jury trial.
A revolver recovered in a Nov 23, 2010 domestic disturbance at a third party’s residence was linked to the defendant by a witness who had seen him with the gun.
Police later recovered the revolver, and the defendant pleaded guilty to possessing it under an Alford plea, which the court later considered in relation to the firearm possession charges.
During trial, the jury acquitted the defendant on the murder/assault/permit counts, while the court found him guilty of criminal possession of a firearm, which was then sentenced to five years with a three-year execution threshold and five years’ probation.
The defendant appealed arguing admission of uncharged misconduct evidence and collateral estoppel; the appellate court affirmed the conviction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of revolver-related evidence	Solomon argues revolver evidence was irrelevant and prejudicial	State contends revolver showed access to means to commit crime and identified defendant	Admission not an abuse; revolver probative of means and identity, not unduly prejudicial
Admission of domestic disturbance evidence	Evidence about domestic disturbance was irrelevant/unduly prejudicial	State could rehabilitate credibility and counter defense theories	Properly admitted to rehabilitate credibility and clarify circumstances
Use of Alford plea to prove possession	Alford plea admissible to show ownership of revolver	Alford plea improper and prejudicial; should not be used as admission	Error harmless; does not affect judgment; limited relevance to ownership not dispositive

State v. Hart, 118 Conn. App. 763 (2010) (trial court evidentiary rulings reviewed for abuse of discretion)
State v. Cutler, 293 Conn. 303 (2009) (uncharged misconduct Evidence—probative value vs prejudice)
State v. Sivri, 46 Conn. App. 578 (1997) (character evidence; admissibility for intent/identity)
State v. Pena, 301 Conn. 669 (2011) (relevance of weapon to show means to commit crime)
State v. Graham, 186 Conn. 437 (1982) (admissibility to rehabilitate a witness)
State v. Daley, 11 Conn. App. 185 (1987) (adversary system; witness credibility rehabilitation)
State v. Mordasky, 84 Conn. App. 436 (2004) (Alford plea considerations)
Lawrence v. Kozlowski, 171 Conn. 705 (1976) (Alford plea lacks currency beyond case)
Groton v. United Steelworkers of America, 254 Conn. 35 (2000) (Alford/plea evidence limitations)
North Carolina v. Alford, 400 U.S. 25 (1970) (Alford plea does not admit guilt; admissibility limits)