State v. Williams

Citations

• 202 Conn. App. 355

Syllabus

The defendant, who had been convicted of the crime of larceny in the first degree, appealed to this court, challenging various evidentiary rulings by the trial court and its denial of her request to secure the attendance at trial of several out-of-state witnesses pursuant to statute (§ 54-82i). The defendant had been a finance director for the state chapter of the American Red Cross and was responsible for reporting payroll informa- tion to P Co., which produced payroll checks and made direct deposits into American Red Cross employees' bank accounts. The defendant was responsible for using SPIN, an online reporting system, to report employee salaries and benefits to the national chapter of the American Red Cross. After the defendant's employment was terminated following a merger of several American Red Cross chapters, her responsibilities were taken over by L, the chief financial officer for the Connecticut American Red Cross. L compared P Co.'s records to the SPIN reports that the defendant had submitted and discovered that the defendant had paid herself $409,647.47 more than she was entitled to while she was employed by the American Red Cross. Thereafter, the defendant gave state police detectives a written, six page statement in which she admitted that she had embezzled money from the American Red Cross. Held: 1. The defendant could not prevail on her claim that the trial court abused its discretion in admitting the SPIN reports into evidence pursuant to the statutory (§ 52-180) business records exception to the rule against hearsay because nothing in L's testimony indicated that the American Red Cross prepared the SPIN reports in the regular course of business; the record plainly indicated that the three statutory requirements for the admissibility of the SPIN reports under the business records exception to the hearsay rule were satisfied, as L testified that the defendant was responsible for submitting individual payroll information to the national chapter of t