Someone else did it: the law of third-party culpability
This post was initially titled “knock me over with a feather” because the CT Supreme Court actually granted [concurrence] a habeas corpus petition today on the grounds of ineffective assistance of counsel. But to go on and on about that would be petty and I am not a petty person, so I’ll restrict my glee to these opening sentences and instead focus on the merits of the claim instead: that trial counsel was ineffective for failing to present testimony from 4 neutral eyewitnesses who would have supported the third-party culpability defense.
If nothing else, this decision serves as a primer on the law of third-party culpability, so it’s more for me than you.
As with everything else, the inquiry starts and ends with relevance:
‘‘The admissibility of evidence of third party culpability is governed by the rules relating to relevancy.’’ (Internal quotation marks omitted.) State v. Ortiz, 252 Conn. 533, 564, 747 A.2d 487 (2000)
‘‘Such evidence is relevant, exculpatory evidence, rather than merely tenuous evidence of third party culpability [introduced by a defendant] in an attempt to divert from himself the evidence of guilt.’’ (Internal quotation marks omitted.) State v. Smith, 280 Conn. 285, 304, 907 A.2d 73 2006). ‘‘In other words, evidence that establishes a direct connection between a third party and the charged offense is relevant to the central question before the jury, namely, whether a reasonable doubt exists as to whether the defendant committed the offense. Evidence that would raise only a bare suspicion that a third party, rather than the defendant, committed the charged offense would not be relevant to the jury’s determination. A trial court’s decision, therefore, that third party culpability evidence proffered by the defendant is admissible, necessarily entails a determination that the proffered evidence is relevant to the jury’s determination of whether a reasonable doubt exists as to the defendant’s guilt.’’ State v. Arroyo, supra, 284 Conn. 609–10.
What is a “more than bare suspicion”? I’ll tell you when I see it. But I do know what “more that bare suspicion” isn’t:
Dunkley v. Commissioner of Correction, 73 Conn. App. 819, 827, 810 A.2d 281 (2002) (no evidence to support third party claim, in part, because no one at scene implicated alleged third party), cert. denied, 262 Conn. 953, 818 A.2d 780 (2003); see also Floyd v. Commissioner of Correction, 99 Conn. App. 526, 531–32, 914 A.2d 1049 (insufficient evidence to substantiate third party claim when predicated on alleged testimony of unlocated drug dealers who were also gang members), cert. denied, 282 Conn. 905, 920 A.2d 308 (2007); Santiago v. Commissioner of Correction, 87 Conn. App. 568, 591–92, 867 A.2d 70 (third party statements did not contain sufficient substance to support viable third party claim), cert. denied, 273 Conn. 930, 873 A.2d 997 (2005); Alvarez v. Commissioner of Correction, 79 Conn. App. 847, 851, 832 A.2d 102 (insufficient evidence to support third party culpability defense when petitioner called only one witness at habeas hearing who did not even observe shooting), cert. denied, 266 Conn. 933, 837 A.2d 804 (2003); Daniel v. Commissioner of Correction, 57 Conn. App. 651, 684, 751 A.2d 398 (testimony not sufficient to raise third party culpability defense because supporting witnesses’ statements were inconsistent), cert. denied, 254 Conn. 918, 759 A.2d 1024 (2000).
So now you know. Sort of.
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about 3 years ago
It’s 3-2. Three say ineffective to Not present the 4 witnesses for a 3rd party culpability defense (which not incidentally also requires that shooting, not beating was cause of death); two say that’s not the problem but it was ineffective to not put on one of those four witness who would have impeached the state’s two snitch wits as to who beat the victim to death. So, what does the new trial lawyer do with this one?
about 3 years ago
What’s all this nonsense about?
They should just use the logical relevance test (ultimate fact in issue more or less likely than it would be without the evidence) coupled with the enforcement of the personal knowledge requirement, with the ability for the prosecution to object because of prejudicial effect substantially outweighs probative value.
This isn’t hard. The personal knowledge requirement eliminates raw speculation (remember in the OJ trial, that knucklehead said that it was a drug hit, even though he had no personal knowledge). The logical relevance test gets rid of the “tenuous” evidence standard, which is meaningless, and if the prejudicial effect will substantially outweigh probative value, then it’s out.