State v. Williams, 317 Conn. 691

DeJesus was the sole eyewitness to a store robbery (Overstock Outlet).
DeJesus had worked at the store for five months and testified the perpetrator had visited the store a couple of times before the robbery, though exact frequency was unclear.
DeJesus could not recall the perpetrator’s prior clothing or faces beyond recognising him when he entered the store.
Defense moved to introduce expert testimony on eyewitness identification; the trial court precluded it and did not make explicit findings about DeJesus’ familiarity with the defendant.
The dissent argues the trial court abused its discretion by precluding the expert testimony because the record lacks clear, sufficient evidence of DeJesus’ familiarity with Williams, and misidentification risks were not clearly shown to be insignificant.
The majority relied on other authorities to justify the preclusion, but the dissent contends the record here is thin and the decision was not supported by Guilbert factors or sufficient findings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the court abused discretion by precluding eyewitness-id expert	Williams argues there was insufficient record to conclude lack of familiarity	State contends DeJesus’ limited interactions do not show sufficient familiarity to reduce misidentification risk	Yes; trial court abused discretion; error harmful and warrants relief

State v. Guilbert, 306 Conn. 218 (Conn. 2012) (recognizes familiarity factors for eyewitness identification and non-reliance on bright-line rules)
State v. Outing, 298 Conn. 34 (Conn. 2010) (concurrence foreshadowing Guilbert framework; familiarity considerations matter)
People v. Abney, 13 N.Y.3d 251 (N.Y. 2009) (eyewitness reliability involving prior exposure can be contested but varies by case)
Johnson v. State, 85 Wis. 2d 22 (Wis. 1978) (prior exposure and familiarity can affect identification reliability)
Parker v. State, 333 Ark. 137 (Ark. 1998) (long-known to eyewitness supports reliability but context matters)