State of Connecticut v. Leotis Payne

Summary

The court affirmed the defendant’s convictions despite concluding that the trial court improperly joined the felony-murder and jury-tampering cases, improperly admitted testimony that the defendant threatened to damage a witness’s van, and permitted three improper prosecutorial remarks. The court held that each error was harmless because the jury received repeated limiting instructions and the evidence of guilt was strong. The court also overruled the prior blanket presumption favoring joinder and clarified the burdens applicable to joinder and prosecutorial-impropriety claims.