State of Connecticut v. Daniel W. E.

Summary

The court affirmed the defendant’s convictions, holding that the trial court’s constancy-of-accusation instruction accurately stated Connecticut law and did not mislead the jury, even though the prosecutor improperly suggested that the evidence corroborated the substance of the victim’s allegations. The court prospectively modified the constancy-of-accusation doctrine: constancy witnesses may testify only when the defendant challenges the victim’s credibility concerning delayed or out-of-court reporting, while the victim may still testify on direct examination about such reports. Justice Espinosa concurred in the result and in the instructional ruling but would have left the existing doctrine unchanged.