State v. Shaw

Summary

The Connecticut Supreme Court reviewed Christopher Shaw’s convictions for first-degree sexual assault and risk of injury to a child. The court held that the trial court improperly excluded proposed evidence concerning the victim’s prior sexual conduct under Connecticut’s rape shield statute, implicating the defendant’s constitutional rights to confrontation and to present a defense. The judgment was reversed and the case was remanded for a new trial.

Holdings

1. The proffered evidence was relevant under General Statutes § 54-86f because it could support an alternative source of the victim's vaginal injuries, challenge her credibility, and show a possible motive for the victim and her mother to fabricate the accusation.
2. The trial court improperly relied on the first two prongs of the State v. Rolon test, which concern prior sexual abuse offered to establish an alternative source of sexual knowledge or confusion about the perpetrator, because the defendant's theory concerned an alternative source of physical injury and fabrication rather than confusion about the perpetrator's identity.
3. The probative value of the evidence outweighed its prejudicial effect, and the trial court abused its discretion by excluding it because it involved alleged sexual conduct between siblings.
4. The exclusion of the prior-sexual-conduct evidence was not harmless beyond a reasonable doubt because the evidence could have affected the jury's assessment of the source of the injuries, the victim's credibility, and the alleged motive to fabricate.

Questions Presented

1. Whether the trial court improperly excluded evidence of the victim's prior sexual conduct under the exceptions in Connecticut's rape shield statute, General Statutes § 54-86f, in violation of the defendant's rights to confrontation, to present a defense, and to due process.
2. Whether the exclusion of the proffered prior-sexual-conduct evidence was harmless beyond a reasonable doubt.

Disposition

reversed_and_remanded