State v. Leniart

Summary

The court held that the defendant's unpreserved corpus delicti challenge was reviewable because Connecticut's rule has both evidentiary and substantive due-process components, but the independent evidence sufficiently corroborated the defendant's confessions and supported the conviction. It further held that excluding the polygraph pretest interview categorically was improper, but the error was harmless, and that excluding the proposed expert testimony concerning incarcerated informants was within the trial court's discretion. Justice Palmer, joined by Justice McDonald, and Justice D'Auria would have found the videotape exclusion harmful; Justice Palmer also would have admitted the expert testimony, while Justice Kahn separately concurred to emphasize limits on admitting references to the polygraph.