State v. Traynham

Citations

• 352 Conn. 582

Syllabus

Convicted of murder, robbery in the first degree, conspiracy to commit robbery in the first degree, carrying a pistol without a permit, and criminal possession of a firearm in connection with the shooting death of the victim, the defendant appealed to this court. The defendant claimed that the trial court had improperly admitted testimony from two witnesses, S and J, about certain statements that R, the defendant's accomplice, had made to them under the statement against penal interest exception to the hearsay rule set forth in the Connecticut Code of Evidence (§ 8-6 (4)). Held: The trial court did not abuse its discretion in admitting the testimony of S and J about R's statements, which inculpated both R and the defendant, under § 8-6 (4) of the Code of Evidence, as R's statements to S and J were against R's penal interest and were sufficiently trustworthy. The defendant conceded that the challenged statements were against R's penal interest, and those statements were trustworthy insofar as R made them voluntarily, in close temporal proximity to the crimes, and to people with whom R had a trusting relationship, namely, a romantic partner, S, and a close family member, J. Moreover, R's statements were corroborated by the evidence presented at trial, and, although there were some discrepancies between R's statements to J and the evidence presented at trial, this court concluded that those inconsistencies, on balance, did not undermine the trustworthiness of the statements to J. Furthermore, although defendant claimed that R's statements were not trust- worthy because R had engaged in blame shifting by attempting to minimize his participation in the homicide, R's statements to S and J nevertheless exposed him to the risk of criminal liability for the same type of crimes 352 Conn. 582 JULY, 2025 583 State v. Traynham with which the defendant was charged, and, therefore, fully and equally implicated both R and the defendant. Argued May 15—officially released July 22, 20