State v. William L.
2011 Conn. App. LEXIS 46
Conn. App. Ct.2011Background
- Defendant William L. resided in his estranged wife's apartment with his wife, their daughter, and the wife's son.
- On September 5, 2007, the victim walked her daughter to the bus stop, shopped, and returned home; the defendant brutally assaulted her in the bedroom, using a knife and threats to coerce sexual intercourse.
- The assault lasted 2–5 minutes; the victim was injured and later provided a rape kit; she informed police after the incident but initially did not call the police to avoid retaliation.
- Police later arrested the defendant after he told a private security guard and then police that he had forced his wife to have sex; he provided a statement at the police station after being advised of his rights.
- A jury convicted the defendant of sexual assault in a spousal relationship under § 53a-70b and sentenced him to fourteen years plus six years of special parole.
- The defense challenged admissibility of lab testimony and constancy of accusation evidence on appeal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether lab report testimony violated confrontation rights | State contends harmless error if any | William L. argues Melendez-Diaz violation | Harmless beyond a reasonable doubt |
| Whether constancy of accusation testimony violated due process rules | State argues admissible under Troupe framework | William L. contends improper admission | Jury admission affirmed; plain error not established |
Key Cases Cited
- Melendez-Diaz v. Massachusetts, 129 S. Ct. 2527 (U.S. 2009) (laboratory reports treated as testimonial; confrontation requirements apply)
- State v. Golding, 213 Conn. 233 (Conn. 1989) (preserves review of unpreserved constitutional claims)
- State v. Troupe, 237 Conn. 284 (Conn. 1996) (constancy of accusation limits testimony about details; balancing test)
- State v. Samuels, 75 Conn.App. 671 (Conn. App. 2003) (limitations on constancy of accusation testimony; reaffirmed approach)
- State v. DePastino, 228 Conn. 552 (Conn. 1994) (treatment-related communications and admissibility context)