Supreme Court of Connecticut
State v. James K.
August 29, 2023347 Conn. 648
Summary
The court affirmed the defendant’s conviction for risk of injury to a child. It clarified that restricting voir dire is reversible error only when the trial court clearly abuses its discretion and the defendant suffers harmful prejudice, and concluded that any limitation here was not prejudicial. It also held that the trial court properly admitted the victim’s forensic interview because the recording contained probative details, the record showed that the court considered prejudice, and the defendant had challenged the recording as a whole rather than seeking redaction.
Holding
- Restriction of voir dire questioning. A limitation on voir dire is reversible error only when the trial court clearly abuses its broad discretion and the defendant suffers harmful prejudice. Even assuming that the trial court clearly abused its discretion by prohibiting questions specifically about parents kissing children on the lips, the defendant failed to establish harmful prejudice.
- Admission of the video-recorded forensic interview. The trial court did not abuse its discretion by admitting the video-recorded forensic interview. The record supported an inference that the court considered the recording’s probative value and prejudicial effect, and the recording was probative because it included details not contained in the victim’s trial testimony and was not unfairly prejudicial.
Docket SC20693
Cited authorities
- 18 U.S.C. § 2265
- Pub. L. No. 117-103, § 106
- 136 Stat. 49