State v. Raynor

Connecticut Supreme Court · 2020 · Evidence

337 Conn. 527 (2020)

Updated August 22, 2026

EvidenceExpert testimonyScientific evidenceUncharged misconductPorter hearingDaubertfirearm and toolmark identificationballistics

Facts

The state alleged that the defendant, a member of Bedrock, shot and killed the victim, a member of a rival gang, from a car on Enfield Street. Thirteen months later, police recovered a .223 caliber Kel-Tec assault rifle, and the state's firearm and toolmark examiner testified that casings from the murder scene and from a later Baltimore Street shooting were fired from that rifle. Before trial, the defendant sought a Porter hearing based on NAS reports criticizing firearm and toolmark methodology and alternatively sought to limit the expert to a "more likely than not" opinion. The state also introduced evidence of the later Baltimore Street shooting, through the victim of that shooting and the examiner, to show identity and access to the weapon.

Issue

Whether the trial court could deny a Porter hearing solely because earlier precedent had treated firearm and toolmark identification as well established, despite the defendant's submission of NAS reports criticizing the methodology. Whether the court also properly refused to limit the expert's conclusions to a "more likely than not" formulation and properly admitted evidence of a subsequent shooting as uncharged misconduct.

Rule

A trial court abuses its discretion if it denies a motion for a Porter hearing solely on the ground that prior case law deemed a scientific methodology well established, without considering new evidence offered to show that the methodology's reliability has been sufficiently called into question. A defendant's challenge does not automatically require a full Porter hearing, but the court must exercise discretion by evaluating the proffered challenge; if a prior Porter hearing exists, a trial court may, but need not, take judicial notice of it when considering the same or additional evidence. Uncharged misconduct admissible for a recognized purpose under § 4-5 (c) must still be excluded when its prejudicial effect outweighs its probative value.

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In a murder trial in New Haven, the state offers footwear-comparison testimony from a forensic examiner to connect crime-scene impressions to boots seized from Omar Vega. Omar moves for a Porter hearing and submits a recent national scientific report criticizing the methodology’s subjectivity and lack of validated error rates, but the trial judge denies the motion solely because an older appellate decision had called footwear comparison a well-established field.

Was the trial judge’s ruling proper?

Explanation. The majority held that scientific reliability is not static. A trial court abuses its discretion if it denies a Porter request solely on the basis of prior precedent deeming a methodology well established, without considering new evidence offered to show the methodology’s reliability has been sufficiently called into question. But the challenge does not automatically require a full hearing.