State v. Echols

50 Citing cases

  1. State v. Rinaldi

    220 Conn. 345 (Conn. 1991)   Cited 58 times
    In Rinaldi, we concluded that evidence pertaining to the victim's sexual conduct on the night of the alleged sexual assault was relevant under the source of semen exception to the rape shield statute, General Statutes § 54-86f, in a case wherein the defendant had claimed that he gave the victim therein a ride home, but did not have sexual relations with her.

    "Although the trial court has wide discretion in its rulings on the relevancy of evidence . . . its rulings will be reversed if the court has abused its discretion or where injustice appears to have been done." State v. Echols, 203 Conn. 385, 393, 524 A.2d 1143 (1987); State v. Smith, 198 Conn. 147, 157, 502 A.2d 874 (1985). Had the trial court been correct in its conclusions, this evidence would not have been barred by General Statutes 54-86f as that statute excludes only the introduction of "evidence of sexual conduct."

  2. State v. Wright

    149 Conn. App. 758 (Conn. App. Ct. 2014)   Cited 11 times
    Holding that defendant's right to fair trial was not impinged, and jury was not misled by court's instruction, where defendant was given opportunity to present evidence and argued to jury regarding deficiencies in police investigation

    “We have recognized consistently that a defendant has a right to introduce evidence that indicates that someone other than the defendant committed the crime with which the defendant has been charged. State v. Sauris, 227 Conn. 389, 401, 631 A.2d 238 (1993); State v. Hernandez, [224 Conn. 196, 202, 618 A.2d 494 (1992) ]; State v. Echols, [203 Conn. 385, 392, 524 A.2d 1143 (1987) ]. The defendant must, however, present evidence that directly connects a third party to the crime.... State v. Hernandez, supra [at], 202 . It is not enough to show that another had the motive to commit the crime ... nor is it enough to raise a bare suspicion that some other person may have committed the crime of which the defendant is accused.... State v. Echols, supra [at], 392 .” (Internal quotation marks omitted.) State v. Cerreta, supra, 260 Conn. at 262–63, 796 A.2d 1176.

  3. Dunkley v. Commissioner of Correction

    73 Conn. App. 819 (Conn. App. Ct. 2002)   Cited 25 times

    "Both this state and other jurisdictions have recognized that a defendant may introduce evidence which indicates that a third party, and not the defendant, committed the crime with which the defendant is charged. . . . The defendant, however, must show some evidence which directly connects a third party to the crime with which the defendant is charged. . . . It is not enough to show that another had the motive to commit the crime . . . nor is it enough to raise a bare suspicion that some other person may have committed the crime of which the defendant is accused. State v. Echols, 203 Conn. 385, 392 [ 524 A.2d 1143 (1987)] . . . State v. Milner, 206 Conn. 512, 517 [ 539 A.2d 80] (1988)." (Emphasis added; internal quotation marks omitted.)

  4. Magnotti v. Meachum

    579 A.2d 553 (Conn. App. Ct. 1990)   Cited 61 times

    He also testified that he knew of the difficulty involved in succeeding in an appeal from a judge's ruling on relevancy because such a ruling will be overturned only for an abuse of discretion. State v. Echols, 203 Conn. 385, 393, 524 A.2d 1143 (1987). In State v. Echols, 203 Conn. 385, 393, 524 A.2d 1143 (1987), our Supreme Court held that "the trial court has wide discretion in its ruling on the relevancy of evidence; State v. McClendon, [ 199 Conn. 5, 8, 505 A.2d 685 (1956)]; State v. Deforge, 194 Conn. 392, 396, 480 A.2d 547 (1984); its rulings will be reversed if the court has abused its discretion or where injustice appears to have been done.

  5. State v. Ashby

    336 Conn. 452 (Conn. 2020)   Cited 7 times
    Observing that this court may presume that legislature was aware of its decision interpreting statute when legislature later passed statutory amendment

    (Citations omitted.) State v. Cerreta , supra, 260 Conn. at 262, 796 A.2d 1176, citing State v. Hernandez , 224 Conn. 196, 202, 618 A.2d 494 (1992) (evidence of threat by third party), and State v. Echols , 203 Conn. 385, 392–94, 524 A.2d 1143 (1987) (evidence that third-party lookalike committed similar crime in same vicinity). By contrast, in State v. West , supra, 274 Conn. at 610, 877 A.2d 787, this court concluded that the trial court did not abuse its discretion by excluding certain forensic evidence recovered from a crime scene.

  6. Bernale Bryant v. Commissioner of Correction

    290 Conn. 502 (Conn. 2009)   Cited 96 times
    In Bryant, the petitioner's trial counsel failed to present four witnesses whose testimony would have supported a third-party culpability defense despite being aware of the witnesses and knowing of their potential testimony.

    There is no requirement that the petitioner specifically name the alleged third party perpetrator. See State v. Echols, 203 Conn. 385, 389, 393-94, 524 A.2d 1143 (1987) (trial court improperly excluded evidence of third party look-alike despite unknown identity). In addition, we conclude that in circumstances that largely involve a credibility contest, as did the petitioner's trial, "the testimony of neutral, disinterested witnesses is exceedingly important."

  7. State v. Francis

    267 Conn. 162 (Conn. 2003)   Cited 24 times

    Third party suspect evidence is admissible if it directly connects the third party to the crime. State v. Echols, 203 Conn. 385, 392, 524 A.2d 1143 (1987). It is not enough [however] to show that another had the motive to commit the crime . . . nor is it enough to raise a bare suspicion that some other person may have committed the crime of which the defendant is accused. . . . State v. Hernandez, supra [202].

  8. State v. Cerreta

    260 Conn. 251 (Conn. 2002)   Cited 66 times
    In Cerreta, on the other hand, the hair and fingerprints at issue were taken from "the victim's body, the ligatures used to bind her hands and feet, and the personal effects on and around her body."

    The restrictions placed on third party culpability evidence are concerned primarily with reliability and, in essence, seek to ensure that a defendant does not introduce tenuous evidence of third party culpability in an attempt to divert from himself the evidence of guilt. See State v. Hernandez, 224 Conn. 196, 202, 618 A.2d 494 (1992); State v. Echols, 203 Conn. 385, 392-93, 524 A.2d 1143 (1987). Those same concerns do not exist under the circumstances of this case, where the evidence the defendant sought to introduce was reliable, physical evidence that had undergone the rigors of forensic analysis.

  9. State v. Rolon

    257 Conn. 156 (Conn. 2001)   Cited 68 times
    In Rolon, the abuse began when the victim was eight months old and continued until she was five years old; see id. at 161–63, 777 A.2d 604; and the issue before the court was whether the victim, because of her very young age, could have confused the defendant with the perpetrator of the prior abuse because of similarities in the type of abuse and in the characteristics of the former perpetrator and the defendant, both of whom were older men and grandfather figures.

    The trial court is vested with wide discretion when considering whether evidence is relevant in a particular case. See State v. Boles, 223 Conn. 535, 549, 613 A.2d 770 (1992); State v. Echols, 203 Conn. 385, 392, 524 A.2d 1143 (1987); see also State v. Kulmac, supra, 230 Conn. 54 (evidence of prior sexual conduct of victim that would be inadmissible under other provisions of statute admissible if otherwise so relevant and material to critical issue in case that excluding it would violate defendant's constitutional rights). Consequently, whether the record supports a defendant's offer of proof on the admissibility of a complainant's prior sexual conduct is a matter to be determined by the trial court on a case-by-case basis.

  10. State v. Ortiz

    252 Conn. 533 (Conn. 2000)   Cited 104 times
    In State v. Ortiz, supra, 252 Conn. 533, the defendants, Angel Luis Ortiz and Julio Diaz-Marrero, claimed that the trial court improperly had declined to instruct the jury regarding the credibility of a witness who had been present during the commission of the crimes with which the defendants were charged.

    We agree. "Both this state and other jurisdictions have recognized that a defendant may introduce evidence which indicates that a third party, and not the defendant, committed the crime with which the defendant is charged. . . . The defendant, however, must show some evidence which directly connects a third party to the crime with which the defendant is charged. . . . It is not enough to show that another had the motive to commit the crime . . . nor is it enough to raise a bare suspicion that some other person may have committed the crime of which the defendant is accused. . . . State v. Echols, 203 Conn. 385, 392, 524 A.2d 1143 (1987); State v. Milner, [supra, 206 Conn. 517]. The admissibility of evidence of third party culpability is governed by the rules relating to relevancy. State v. Echols, supra, 393; State v. Giguere, 184 Conn. 400, 405-406, 439 A.2d 1040 (1981).