State v. Webb, 128 Conn. App. 846

In 2007, the state charged Webb with four murders across two dockets (CR-07-222067 and CR-07-222068).
The state moved to consolidate the four murder counts; Webb objected and sought severance.
In May 2008, the court consolidated Sharon C., Minnie S., and Elizabeth G. murders; Sheila E. remained separate.
The court ruled Evelyn C.’s death in Georgia was admissible as uncharged misconduct to prove identity in all cases.
Plea agreement followed: Webb entered nolo contendre pleas to three murders; sentencing was 60 years concurrent.
Webb challenged the consolidation and the admissibility ruling on appeal; the judgments were affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether consolidation was proper for identity evidence	State contends joinder was proper due to cross-admissible identity evidence.	Webb argues consolidation caused undue prejudice and lack of severance benefits.	Consolidation proper; cross admissible identity evidence supports joinder.
Whether Evelyn C. evidence was admissible for identity	State asserts Evelyn C. evidence shares distinctive features tying it to the others.	Webb contends Evelyn C. evidence is improperly admitted uncharged misconduct.	Admissible uncharged misconduct evidence to prove identity.

State v. Gupta, 297 Conn. 211 (Conn. 2010) (presumption in favor of joinder and against severance)
State v. McKenzie-Adams, 281 Conn. 486 (Conn. 2007) (joinder of offenses; standard for severance)
State v. King, 35 Conn.App. 781 (Conn. App. 1994) (joinder of charges is the norm; abuse of discretion standard)
State v. Boyd, 295 Conn. 707 (Conn. 2010) (identity evidence; standard for admissibility of other misconduct)
State v. Figueroa, 235 Conn. 145 (Conn. 1995) (two-prong analysis for other crimes evidence)
State v. Carty, 100 Conn.App. 40 (Conn. App. 2007) (identity evidence; distinctive signature must exist)
State v. Orr, 291 Conn. 642 (Conn. 2009) (abuse of discretion standard in evidentiary rulings)