State v. Dixon

Citations

• 353 Conn. 382

Syllabus

Convicted of manslaughter in the first degree with a firearm, the defendant appealed to this court. The defendant's conviction stemmed from an incident in which he and two friends encountered the victim and his friend, G, whom the defendant had previously assaulted. G witnessed the defendant pull a gun from his waistband, and, as G and the victim fled, a shot was fired, which ultimately struck and killed the victim. On appeal, the defendant claimed, inter alia, that the trial court improperly allowed C, one of the state's witnesses, to testify as an expert about neighborhoods, neighborhood 353 Conn. 382 SEPTEMBER, 2025 383 State v. Dixon divisions, and the dynamics between neighborhoods in Stamford, the city in which the victim's killing occurred. Held: The defendant could not prevail on his claim that his right to due process was violated insofar as C implicitly invoked racial stereotypes when he characterized the Black residents in certain Stamford neighborhoods as being engaged in firearms and drug trafficking, and in violent criminal activ- ity, as C never testified before the jury regarding the demographics of the various Stamford neighborhoods, or regarding race in general, and, even though C did testify about firearms and drug trafficking in Stamford, he did not connect those activities to specific neighborhoods or the Black residents in those neighborhoods. The trial court abused its discretion when it permitted C to offer expert testimony about various Stamford neighborhoods, neighborhood divisions, and the dynamics between them. C's ''neighborhood'' testimony amounted to testimony about gang activity in various Stamford neighborhoods, and, because the state conceded that there was no evidence that the defendant was a member of a gang, such testimony had limited probative value, and any probative value was out- weighed by the danger of unfair prejudice. Moreover, C's testimony was not the proper subject of expert testimony simply because it may have been re