State v. John M., 285 Conn. 822

Summary

The Connecticut Supreme Court affirmed the Appellate Court's judgment upholding the defendant's convictions for sexual assault and risk of injury to a child. The court addressed whether the trial court improperly excluded evidence concerning the alleged coaching of the victim by the defendant's former wife and the former wife's alleged animus toward the defendant. It concluded that the record was inadequate to review the coaching claim and that any evidentiary errors were harmless beyond a reasonable doubt.

Holdings

1. The record was inadequate to review the defendant's claim because he made no factual proffer detailing M.'s alleged statements concerning her own abuse. Even assuming the claim could be reviewed and that the testimony should have been admitted, any error was harmless beyond a reasonable doubt.
2. The court need not decide whether the trial court improperly excluded testimony concerning M.'s belief that the defendant would return to her because any error was harmless beyond a reasonable doubt.
3. The constitutional right to present a defense does not entitle a criminal defendant to introduce every item of evidence he wishes; relevant evidence may be introduced subject to ordinary evidentiary rules, and irrelevant evidence may be excluded.

Questions Presented

1. Whether the exclusion of testimony concerning M.'s alleged history of sexual abuse deprived the defendant of his constitutional right to present a defense.
2. Whether the exclusion of testimony concerning M.'s alleged animus toward the defendant deprived the defendant of a fair trial.
3. Whether any error in excluding either category of evidence was harmless beyond a reasonable doubt.

Disposition

affirmed