State v. Leniart

Summary

The court held that the defendant’s unpreserved corpus delicti claim was reviewable because Connecticut’s rule has both evidentiary and substantive due process components, but concluded that independent evidence sufficiently corroborated the defendant’s confessions and supported the convictions. It held that the trial court improperly excluded the polygraph pretest interview categorically, but that the error was harmless, and that the trial court properly exercised its discretion in excluding expert testimony concerning incarcerated informants because the testimony would not have materially assisted the jury. Justice Palmer, joined by Justice McDonald, and Justice D’Auria, concurring in part and dissenting in part, would have treated the videotape error as harmful; Justice Kahn concurred while emphasizing limits on admitting references to the polygraph.