State v. Wright, 73 A.3d 828

Background

Victim went to a vacant apartment expecting payment for sexual services; multiple men (including Wright) then engaged in nonconsensual sexual acts over ~1.5 hours; victim later reported the assault and submitted to a sexual assault kit.
Wright was tried and convicted of two counts of first‑degree aggravated sexual assault, one count of conspiracy to commit aggravated sexual assault, conspiracy to commit kidnapping, third‑degree assault, and conspiracy to commit third‑degree assault; acquitted of first‑degree kidnapping.
Prior to trial the state moved under the rape‑shield statute (Conn. Gen. Stat. §54‑86f) to exclude evidence of the victim’s prior sexual conduct unless an exception applied; the court conducted a §54‑86f hearing.
The court initially limited defense cross‑examination about the victim’s prostitution and recent paid sex but allowed the defendant to present such evidence in his case‑in‑chief once he had shown a factual basis; after introduction of the defendant’s statement the court found consent was sufficiently raised and permitted inquiry.
On appeal Wright argued (1) improper exclusion of evidence relevant to consent and victim bias (constitutional confrontation/presentation of defense claim), and (2) federal double jeopardy violation because three conspiracy convictions arose from one agreement.
The appellate court affirmed the evidentiary rulings (finding the jury had access to the proffered facts and the term “prostitute” was not necessary) but reversed as to the three conspiracy convictions, directing vacatur of two and entry of judgment on a single conspiracy count with resentencing.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility under Conn. Gen. Stat. §54‑86f / right to confront & present a defense	State: Rape‑shield statute and its exceptions governed; court properly carried out §54‑86f balancing and limited prejudicial testimony until consent was sufficiently raised.	Wright: Exclusion prevented proof that victim was a prostitute who had just consensually traded sex for money (showing consent or motive to fabricate), violating his confrontation and defense rights.	Court: No constitutional violation — jury received the factual evidence (even if the label “prostitute” was barred); once consent was sufficiently raised defense could present prior sexual conduct; ruling affirmed.
Double jeopardy from multiple conspiracy convictions	State: Multiple conspiracy judgments may be corrected by vacating sentences or combining convictions consistent with precedent.	Wright: Three conspiracy convictions arose from a single agreement; multiple punishments violate double jeopardy — vacate two conspiracies and leave one.	Court: Agreed double jeopardy violated; reversed convictions for the three conspiracies and remanded to enter judgment on one conspiracy and resentence (vacate two conspiracy counts).

Key Cases Cited

State v. DeJesus, 270 Conn. 826 (Conn. 2004) (framework for §54‑86f and confrontation/defense issues)
State v. Polanco, 308 Conn. 242 (Conn. 2013) (remedy for cumulative convictions violating double jeopardy)
State v. Gonzalez, 302 Conn. 287 (Conn. 2011) (two‑step same‑transaction / same‑offense double jeopardy analysis)
State v. Rolon, 257 Conn. 156 (Conn. 2001) (requiring clear statement of defense theory of relevance)
State v. Adorno, 121 Conn. App. 534 (Conn. App. 2010) (deference to trial court on relevancy and scope of cross‑examination)
State v. Lee, 138 Conn. App. 420 (Conn. App. 2012) (single agreement cannot support multiple conspiracy punishments)
State v. LaFleur, 307 Conn. 115 (Conn. 2012) (aggregate sentencing package doctrine discussed)
Golding v. State, 213 Conn. 233 (Conn. 1989) (preservation and standard for addressing unpreserved constitutional claims)
Demers v. State, 209 Conn. 143 (Conn. 1988) (guidance on rape‑shield balancing)