State v. Vere C., 152 Conn.App. 486

The defendant Vere C. was convicted after a jury trial of multiple sexual offenses against three minor children (S.G., N.W., K.C.) who were in his care.
He lived with the mothers of the children (U.G. and M.S.) and provided child care from about 2003 to 2010, during which time the abuses occurred.
The alleged offenses included sexual intercourse, oral sex, and sexual contact with the victims, occurring in various residences while the children were in his care.
The state introduced uncharged misconduct evidence involving S.F. (the defendant’s biological daughter) to show propensity; the court gave limiting instructions.
The state also offered constancy of accusation testimony from E.F. about S.F.’s prior complaints; the defense challenged but the court admitted it under applicable rules.
The defendant challenged several rulings—admission of prior misconduct, constancy of accusation, cross-examination limits, unanimity of counts, severance, and sufficiency of counts 12 and 14—and the appellate court affirmed the trial court’s judgment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admission of uncharged misconduct evidence under DeJesus	State argues evidence shows propensity to abuse children.	Vere C. contends evidence is dissimilar and prejudicial.	Admissible with limiting instructions under DeJesus framework.
Constancy of accusation evidence by E.F.	E.F. testimony connected to S.F.’s prior allegations.	Testimony inappropriate as constancy of accusation for a non-complainant.	Harmless error; evidence cumulative and not likely to sway verdict.
Limitation of cross-examination of S.G. regarding false statement about mother	Cross-exam should illuminate credibility.	Right to confrontation requires broader cross-examination.	No constitutional violation; cross-examination limits were within trial court discretion.
Unanimity of counts seven, eight, nine with an amended information	Counts describe multiple acts within a time frame.	Broad wording risks nonunanimous verdicts.	No nonunanimous verdict; jury instructed to verdict unanimously on each count.
Joinder/severance of counts (S.G. vs. N.W./K.C.)	Joinder appropriate for related sexual offenses.	Severance needed to avoid prejudice from disparate charges.	Trial court did not abuse discretion; substantial prejudice not shown.

State v. DeJesus, 288 Conn. 418 (2008) (limited propensity exception for uncharged sex misconduct evidence)
State v. Allen, 140 Conn. App. 423 (2013) (limitations on uncharged misconduct evidence; similar acts requirement)
State v. L.W., 122 Conn. App. 324 (2010) (no bright-line test for similarity; acts need not be identical)
State v. Crespo, 303 Conn. 589 (2012) (confrontation and cross-examination standards; relevance)
State v. Mark R., 300 Conn. 590 (2011) (confrontation clause limits on cross-examination)
State v. Dyson, 238 Conn. 784 (1996) (standard for assessing duplicity and unanimity when multiple acts are charged)
State v. Payne, 303 Conn. 538 (2012) (burden shifting on joinder; same-character analysis)
State v. Webb, 128 Conn. App. 846 (2011) (joinder and cross-admissibility principles; similar character evidence)
State v. Marcelino S., 118 Conn. App. 589 (2009) (credibility and prosecutorial notice in sexual abuse cases; duplicity concerns)
State v. Jessie L. C., 148 Conn. App. 216 (2014) (unanimity and jury instruction standards in multi-count trials)