State v. Williams

Citations

• 350 Conn. 363

Syllabus

The defendant appealed from the judgment of conviction of murder and criminal possession of a firearm. The defendant claimed, inter alia, that the evidence was insufficient to support the jury's verdict and that the trial court had deprived him of his constitutional right to present a defense when 364 NOVEMBER, 2024 350 Conn. 363 State v. Williams it precluded his expert witness from testifying about certain surveillance footage. Held: The evidence, when construed in the light to most favorable to sustaining the verdict, was sufficient to support the jury's verdict, as the defendant did not dispute that the state presented sufficient evidence to prove the elements of the charged offenses beyond a reasonable doubt, and the physi- cal evidence presented at trial, which potentially conflicted with eyewitness testimony, did not render the state's theory of the case that the defendant had shot the victim from inside of the defendant's vehicle a physical impossibility. The trial court improperly applied the standard for determining the admissi- bility of an identification by a nonpercipient witness instead of the standard applicable to the admission of expert testimony when it precluded the defendant's expert, a private investigator with expertise in video analysis, from testifying about his observations of certain surveillance footage, and, because the trial court's error was not harmless, this court reversed the judgment of conviction and remanded the case for a new trial. The trial court did not abuse its discretion in admitting expert testimony that one and two element particles ''commonly associated with'' and ''consistent with'' gunshot residue were detected on the defendant's hands and clothing, and in his vehicle, as courts have routinely admitted such testimony and the probative value of the testimony was not outweighed by the danger of unfair prejudice. Argued February 16—officially released August 13, 2024