State v. Walker, 175 A.3d 576

Defendant Joseph Walker arranged to buy cocaine from victim David Caban; during the transaction Walker and an accomplice Solomon Taylor shot and killed Caban and drove away.
After the shooting Walker and Taylor returned to Taylor's girlfriend Alexia Bates' apartment; Bates discovered blood and the revolver in her car and, at Taylor's orders and under threat, helped clean the vehicle and remove items.
Bates was charged with tampering with evidence and testified for the state; there was an agreement for leniency in her pending case in exchange for her testimony.
Walker was convicted of murder, conspiracy to commit murder, robbery in the first degree, conspiracy to commit robbery, and criminal possession of a firearm; this appeal concerns whether the trial court erred, sua sponte, by failing to give an accomplice-testimony credibility instruction regarding Bates.
The Connecticut Appellate Court originally found Walker had waived the claim; the Supreme Court granted certification and remanded to consider plain error in light of State v. McClain.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court committed plain error by failing, sua sponte, to instruct the jury that Bates' testimony should be viewed with caution as accomplice testimony	State: No plain error; no instruction required because evidence did not show Bates was an accomplice to the charged offenses	Walker: Bates aided in the cover-up (cleaning the car), was charged with tampering, and had incentive (leniency) to curry favor—so the court should have given an accomplice credibility instruction	Court: No plain error. Bates was not present during the murder, did not share a criminal intent or intentionally aid the robbery/murder, and acted under duress when cleaning the car; an accomplice instruction was not warranted

State v. McClain, 324 Conn. 802, 155 A.3d 209 (2017) (plain error review may consider instructional claims despite implied waiver)
State v. Boles, 223 Conn. 535, 613 A.2d 770 (1992) (absence of mutuality of intent/community of unlawful purpose can make an accomplice instruction unnecessary; omission not necessarily plain error)
State v. Jamison, 320 Conn. 589, 134 A.3d 560 (2016) (explaining plain error doctrine and its demanding standard)
State v. Diaz, 302 Conn. 93, 25 A.3d 594 (2011) (trial court not required to give special credibility instruction whenever a witness may receive a benefit)
State v. Underwood, 142 Conn. App. 666, 64 A.3d 1274 (2013) (trial court duty to give accomplice instruction arises only where evidence supports that the witness intentionally aided the commission of the charged offense)