State v. Myers

Citations

• 352 Conn. 770

Syllabus

Convicted of murder in connection with the stabbing death of the victim, the defendant's former girlfriend, the defendant appealed to this court. Prior to trial, the trial court denied in part the defendant's motion to introduce third-party culpability evidence relating to the victim's neighbor, A. The trial court specifically excluded a video that A had sent to the victim and related text messages, a voicemail that A had left for his girlfriend after the police interviewed him about the victim's murder, evidence of A's prior misconduct, and evidence of a decline in A's mental health in the weeks following the victim's murder. The defendant claimed, inter alia, that the trial court had abused its discretion in excluding the foregoing evidence and that its exclu- sion violated his constitutional rights to due process, to present a complete defense, and to confrontation. Held: Even if this court assumed that the trial court had abused its discretion in excluding the proffered evidence, any error was evidentiary rather than constitutional in nature, and the defendant failed to satisfy his burden of demonstrating that the error was harmful. Any claimed error in the exclusion of the proffered evidence did not deprive the defendant of his constitutional rights because, even though the excluded evidence concerned A's relationship with the victim and his behavior follow- ing the murder, it was not central to the defendant's third-party culpability 352 Conn. 770 AUGUST, 2025 771 State v. Myers defense, and the defendant nevertheless was able to present to the jury substantial evidence and argument in support of that defense. Moreover, this court had a fair assurance that the trial court's exclusion of the proffered evidence did not affect the jury's verdict given the overall strength of the state's case and the weakness of the defendant's third-party culpability defense, and the fact that most of the evidence supporting the defendant's third-party culpability defense was adm