State v. Wright, 140 A.3d 939

Victim Ronald Bethea was shot outside a New Haven bar on April 27, 2008; surveillance video (grainy) showed a perpetrator approach and shoot him from behind. The state’s case was entirely circumstantial.
Four New Haven police officers testified for the state about their roles; defense cross-examination probed omissions in the officers’ investigation (failure to obtain IDs, canvass nearby homes, test fibers, etc.).
Trial court repeatedly sustained state objections limiting defense questions to the specific actions taken during this investigation and disallowed broader questioning about officers’ practices in other cases or general departmental procedures.
Defense attempted a limited offer of proof (two questions to Officer McNeil); did not qualify any officer as an expert, did not proffer documentary SOPs or other witnesses, and never developed a foundation showing routine practices existed or were violated.
Jury convicted Wright of murder; Appellate Court reversed, holding the trial court’s limits improperly prevented the defendant from comparing the investigation to ordinary police practices. The Supreme Court granted certification on two issues and reversed the Appellate Court.

Issue	State's Argument	Wright's Argument	Held
Whether trial court abused discretion by precluding defense from asking officers about general police practices/procedures and comparisons to other investigations	Trial court did not abuse discretion; broader questioning required foundation (expert qualification, routine practice evidence) and relevance to this case	Defense argued it needed to show that officers deviated from customary practices to support an inadequate-investigation defense and to contextualize omissions	No abuse: without a sufficient offer of proof (no expert qualification, no evidence of standard practices or that deviations could yield material evidence), limiting cross-examination was proper
Whether evidentiary limitations deprived defendant of constitutional right to present a defense / fair trial	Any limitation upheld because defense failed to lay foundation; record permitted inquiry into what officers did/didn’t do in this case	Trial court’s limits prevented meaningful presentation of an inadequate-investigation defense	No deprivation: defendant failed to provide adequate offer of proof or foundation showing that excluded inquiry would have been relevant and likely to produce material evidence; conviction affirmed

State v. Collins, 299 Conn. 567 (recognizes that defendants may use investigation deficiencies to raise reasonable doubt)
Kyles v. Whitley, 514 U.S. 419 (acknowledging challenge to investigative adequacy as common defense strategy)
Commonwealth v. Silva-Santiago, 453 Mass. 782 (evidence police failed to pursue leads/tests can support inadequate-investigation inference)
Sample v. State, 314 Md. 202 (defendant may comment on absence of readily available superior methods of proof)
People v. Hayes, 17 N.Y.3d 46 (right to cross-examine not absolute; relevance and foundation required)
State v. Brown, 273 Conn. 330 (trial court may exclude questioning that would divert jury to collateral departmental standards)
State v. Benedict, 313 Conn. 494 (proffering party bears burden to establish relevance via offer of proof or record)
State v. Esposito, 235 Conn. 802 (defendant must make sufficient offer of proof; court may allow unrestricted offer)
State v. Shaw, 312 Conn. 85 (offer of proof must show relevance of proffered testimony)
State v. Bova, 240 Conn. 210 (insufficient offer of proof fails to establish relevancy)
State v. Brunetti, 279 Conn. 39 (defendant must preserve adequate record for appellate review)
State v. Campbell, 225 Conn. 650 (police may be qualified as expert witnesses on basis of training/experience)
State v. Girolamo, 197 Conn. 201 (same)
State v. Cosgrove, 181 Conn. 562 (same)