State v. William G., 232 Conn.App. 317

William G. was convicted by a jury in Connecticut of first and second-degree sexual assault against his stepdaughter, primarily based on her delayed report of abuse and her testimony.
The case critically relied on the victim's credibility, with the defense focusing on the inconsistencies and delays in her disclosures as a primary theory of defense.
The trial court instructed the jury, following then-binding precedent (Daniel W.E.), not to consider the victim’s delayed reporting in evaluating her credibility.
After the trial but during the appeal, the Connecticut Supreme Court decided State v. Adam P., overturning Daniel W.E. and reinstating the rule from Troupe that juries should be permitted to consider delayed reporting when weighing credibility.
The state also introduced uncharged misconduct evidence to show propensity; the trial court instructed the jury using the standard model instruction, rejecting the defense's request for a preponderance-of-the-evidence finding for such misconduct.

Issue	William G.'s Argument	State's Argument	Held
Jury instruction on delayed reporting	Instruction erroneously barred jury from considering key defense (delayed report undermines credibility)	At time of trial, instruction followed prevailing law; effect not harmful	Instruction was improper and harmful; new trial required
Instruction re: uncharged misconduct evidence	Jury must find such conduct occurred by preponderance before considering it for propensity	Existing model instruction is adequate and law does not require preponderance finding	Trial court’s limiting instruction on misconduct evidence was proper

State v. Troupe, 677 A.2d 917 (Conn. 1996) (established that delay in reporting is for jury consideration re: credibility)
State v. Adam P., 330 A.3d 73 (Conn. 2025) (reinstated Troupe's rule post-Daniel W.E.; applies retroactively)
State v. Cutler, 977 A.2d 209 (Conn. 2009) (no requirement for preponderance standard for uncharged misconduct jury instruction)