Porter hearing in Connecticut

2022Held that the trial court did not abuse its discretion in admitting the evidence of uncharged misconduct tying the firearm used in the prior shootings to the firearm used in the murders of the victims to prove that the defendant was the individual who shot the victims: the defendant’s claim challenging the relevance of J’s testimony in light of its lack of scientific reliability was unavailing, as the defendant’s failure to request a hearing pursuant to State v. Porter ( 241 Conn. 57 ) deprived the trial court of the opportunity to assess J’s methodology and, thus, the reliability of J’s testi

2022Held that the trial court did not abuse its discretion in admitting the evidence of uncharged misconduct tying the firearm used in the prior shootings to the firearm used in the murders of the victims to prove that the defendant was the individual who shot the victims: the defendant’s claim challenging the relevance of J’s testimony in light of its lack of scientific reliability was unavailing, as the defendant’s failure to request a hearing pursuant to State v. Porter ( 241 Conn. 57 ) deprived the trial court of the opportunity to assess J’s methodology and, thus, the reliability of J’s testi

2022The defendant concedes that whether Jachimowicz should have been able to testify as an expert in this case is not reviewable by this court, as he did not request a hearing at trial pursuant to State v. Porter, 241 Conn. 57 , 81-90, 698 A.2d 739 (1997), cert. denied, 523 U.S. 1058 , 118 S. Ct. 1384 , 140 L. Ed. 2d 645 (1998), and acknowledges that a Porter hearing ‘‘is the proper way to challenge the admissibility of an expert’s opinion based on the validity of the methodology underlying that opinion.’’ Instead, through his relevancy objection to the prior misconduct evidence, the defendant att

2022The defendant concedes that whether Jachimowicz should have been able to testify as an expert in this case is not reviewable by this court, as he did not request a hearing at trial pursuant to State v. Porter, 241 Conn. 57 , 81-90, 698 A.2d 739 (1997), cert. denied, 523 U.S. 1058 , 118 S. Ct. 1384 , 140 L. Ed. 2d 645 (1998), and acknowledges that a Porter hearing ‘‘is the proper way to challenge the admissibility of an expert’s opinion based on the validity of the methodology underlying that opinion.’’ Instead, through his relevancy objection to the prior misconduct evidence, the defendant att

2024See State v. Raynor, 337 Conn. 527 , 540-41, 254 A.3d 874 (2020). ‘‘In Porter, this court followed the United States Supreme Court’s decision in Daubert v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579 , 113 S. Ct. 2786 , 125 L. Ed. 2d 469 (1993), and held that scientific evidence should be subjected to a flexible test, with differing factors that are applied on a case-by-case basis, to determine the reliability of the scientific evidence.’’ State v. Reid, 254 Conn. 540, 545 , 757 A.2d 482 (2000). ‘‘A Porter analysis involves a two part inquiry that assesses the reliability and relevance of

2024See State v. Raynor, 337 Conn. 527 , 540-41, 254 A.3d 874 (2020). ‘‘In Porter, this court followed the United States Supreme Court’s decision in Daubert v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579 , 113 S. Ct. 2786 , 125 L. Ed. 2d 469 (1993), and held that scientific evidence should be subjected to a flexible test, with differing factors that are applied on a case-by-case basis, to determine the reliability of the scientific evidence.’’ State v. Reid, 254 Conn. 540, 545 , 757 A.2d 482 (2000). ‘‘A Porter analysis involves a two part inquiry that assesses the reliability and relevance of

2026As we have recognized, some scientific principles have become so well established that [a threshold admissibility] analysis is not necessary for admission of evidence thereunder.” (Internal quotation marks omitted.) Id., 169 .

2013In one line of cases, “we have concluded that certain forms of scientific evidence have become so well established that a formal Porter inquiry is rendered unnecessary . . . .” Id., 170 ; see State v. Porter, supra, 241 Conn. 85 n.30 , citing State v. Cline, 275 Mont. 46, 55 , 909 P.2d 1171 (1996) (ordinary fingerprint identification evidence); see also Hayes v. Decker, 263 Conn. 677, 687-89 , 822 A.2d 228 (2003) (effects of discontinuation of blood pressure medication); State v. Kirsch, 263 Conn. 390, 405 , 820 A.2d 236 (2003) (reliability of alcohol blood testing done at hospital well establ

2011The dissent specifically contends that the defendant preserved her claim when she filed her motion for a Porter hearing; see State v. Porter, 241 Conn. 57 , 698 A.2d 739 (1997), cert, denied, 523 U.S. 1058 , 118 S. Ct. 1384 , 140 L.

2011The dissent specifically contends that the defendant preserved her claim when she filed her motion for a Porter hearing; see State v. Porter, 241 Conn. 57 , 698 A.2d 739 (1997), cert, denied, 523 U.S. 1058 , 118 S. Ct. 1384 , 140 L.

2025A Porter analysis involves a two part inquiry that assesses the reliability and relevance of the witness’ methods.’’ (Internal quotation marks omitted.) State v. Edwards, 325 Conn. 97, 124 , 156 A.3d 506 (2017). 38 ,0 0 Conn. 1 State v. Cooper to those answers.

2025A Porter analysis involves a two part inquiry that assesses the reliability and relevance of the witness’ methods.’’ (Internal quotation marks omitted.) State v. Edwards, 325 Conn. 97, 124 , 156 A.3d 506 (2017). 38 ,0 0 Conn. 1 State v. Cooper to those answers.

2026See Weaver v. McKnight, 313 Conn. 393 , 415-16, 97 A.3d 920 (2014) (“[t]he failure to raise a Porter claim in the trial court results in waiver of that claim and it will not be considered for the first time on appeal”). 7 As discussed in part II of this opinion, the defendant’s failure to provide complete transcripts precludes our review of any claims that would require us to review the entire record to assess whether the trial court’s conclusion is supported by the evidence presented to it.

2026See Weaver v. McKnight, 313 Conn. 393 , 415-16, 97 A.3d 920 (2014) (“[t]he failure to raise a Porter claim in the trial court results in waiver of that claim and it will not be considered for the first time on appeal”). 7 As discussed in part II of this opinion, the defendant’s failure to provide complete transcripts precludes our review of any claims that would require us to review the entire record to assess whether the trial court’s conclusion is supported by the evidence presented to it.

2010Without such an articulation, the trial court is entirely ill-equipped to determine if the scientific evidence is reliable upon consideration of the various Porter factors.” Prentice v. Dalco Electric, Inc., 280 Conn. 336, 345 , 907 A.2d 1204 (2006), cert. denied, 549 U.S. 1266 , 127 S. Ct. 1494 , 167 L.

2010Without such an articulation, the trial court is entirely ill-equipped to determine if the scientific evidence is reliable upon consideration of the various Porter factors.” Prentice v. Dalco Electric, Inc., 280 Conn. 336, 345 , 907 A.2d 1204 (2006), cert. denied, 549 U.S. 1266 , 127 S. Ct. 1494 , 167 L.

2014See State v. Porter, supra, 241 Conn. 146 (‘‘‘[t]he inquiry . . . is, we empha- size, a flexible one’ ’’); see also State v. Griffin, 273 Conn. 266, 276 , 869 A.2d 640 (2005) (acknowledging that Porter requires flexible, case-by-case approach); Hayes v. Decker, 263 Conn. 677 , 685 n.2, 822 A.2d 228 (2003) (trial court found to be in error for applying Porter inquiry mechanically).

2014See State v. Porter, supra, 241 Conn. 146 (‘‘‘[t]he inquiry . . . is, we empha- size, a flexible one’ ’’); see also State v. Griffin, 273 Conn. 266, 276 , 869 A.2d 640 (2005) (acknowledging that Porter requires flexible, case-by-case approach); Hayes v. Decker, 263 Conn. 677 , 685 n.2, 822 A.2d 228 (2003) (trial court found to be in error for applying Porter inquiry mechanically).

2024See State v. Raynor, 337 Conn. 527 , 540-41, 254 A.3d 874 (2020). ‘‘In Porter, this court followed the United States Supreme Court’s decision in Daubert v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579 , 113 S. Ct. 2786 , 125 L. Ed. 2d 469 (1993), and held that scientific evidence should be subjected to a flexible test, with differing factors that are applied on a case-by-case basis, to determine the reliability of the scientific evidence.’’ State v. Reid, 254 Conn. 540, 545 , 757 A.2d 482 (2000). ‘‘A Porter analysis involves a two part inquiry that assesses the reliability and relevance of

2024See State v. Raynor, 337 Conn. 527 , 540-41, 254 A.3d 874 (2020). ‘‘In Porter, this court followed the United States Supreme Court’s decision in Daubert v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579 , 113 S. Ct. 2786 , 125 L. Ed. 2d 469 (1993), and held that scientific evidence should be subjected to a flexible test, with differing factors that are applied on a case-by-case basis, to determine the reliability of the scientific evidence.’’ State v. Reid, 254 Conn. 540, 545 , 757 A.2d 482 (2000). ‘‘A Porter analysis involves a two part inquiry that assesses the reliability and relevance of

2013In one line of cases, “we have concluded that certain forms of scientific evidence have become so well established that a formal Porter inquiry is rendered unnecessary . . . .” Id., 170 ; see State v. Porter, supra, 241 Conn. 85 n.30 , citing State v. Cline, 275 Mont. 46, 55 , 909 P.2d 1171 (1996) (ordinary fingerprint identification evidence); see also Hayes v. Decker, 263 Conn. 677, 687-89 , 822 A.2d 228 (2003) (effects of discontinuation of blood pressure medication); State v. Kirsch, 263 Conn. 390, 405 , 820 A.2d 236 (2003) (reliability of alcohol blood testing done at hospital well establ

2013In one line of cases, “we have concluded that certain forms of scientific evidence have become so well established that a formal Porter inquiry is rendered unnecessary . . . .” Id., 170 ; see State v. Porter, supra, 241 Conn. 85 n.30 , citing State v. Cline, 275 Mont. 46, 55 , 909 P.2d 1171 (1996) (ordinary fingerprint identification evidence); see also Hayes v. Decker, 263 Conn. 677, 687-89 , 822 A.2d 228 (2003) (effects of discontinuation of blood pressure medication); State v. Kirsch, 263 Conn. 390, 405 , 820 A.2d 236 (2003) (reliability of alcohol blood testing done at hospital well establ

2014The Appellate Court relied on our decision in Klein v. Norwalk Hospital, 299 Conn. 241 , 9 A.3d 364 (2010), a case applying a Porter analysis.

2014The Appellate Court relied on our decision in Klein v. Norwalk Hospital, 299 Conn. 241 , 9 A.3d 364 (2010), a case applying a Porter analysis.

2024See State v. Raynor, 337 Conn. 527 , 540-41, 254 A.3d 874 (2020). ‘‘In Porter, this court followed the United States Supreme Court’s decision in Daubert v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579 , 113 S. Ct. 2786 , 125 L. Ed. 2d 469 (1993), and held that scientific evidence should be subjected to a flexible test, with differing factors that are applied on a case-by-case basis, to determine the reliability of the scientific evidence.’’ State v. Reid, 254 Conn. 540, 545 , 757 A.2d 482 (2000). ‘‘A Porter analysis involves a two part inquiry that assesses the reliability and relevance of

2024See State v. Raynor, 337 Conn. 527 , 540-41, 254 A.3d 874 (2020). ‘‘In Porter, this court followed the United States Supreme Court’s decision in Daubert v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579 , 113 S. Ct. 2786 , 125 L. Ed. 2d 469 (1993), and held that scientific evidence should be subjected to a flexible test, with differing factors that are applied on a case-by-case basis, to determine the reliability of the scientific evidence.’’ State v. Reid, 254 Conn. 540, 545 , 757 A.2d 482 (2000). ‘‘A Porter analysis involves a two part inquiry that assesses the reliability and relevance of

2020In State v. Griffin, supra, 273 Conn. 266 , our Supreme Court recited the analytic framework for determining whether a Porter analysis is necessary and summarized its decision in Reid and Hasan. ‘‘[O]ur initial inquiry is whether the [evidence] at issue . . . is the type of evidence contemplated by Porter. . . .

2020In State v. Griffin, supra, 273 Conn. 266 , our Supreme Court recited the analytic framework for determining whether a Porter analysis is necessary and summarized its decision in Reid and Hasan. ‘‘[O]ur initial inquiry is whether the [evidence] at issue . . . is the type of evidence contemplated by Porter. . . .

2010Without such an articulation, the trial court is entirely ill-equipped to determine if the scientific evidence is reliable upon consideration of the various Porter factors.” Prentice v. Dalco Electric, Inc., 280 Conn. 336, 345 , 907 A.2d 1204 (2006), cert. denied, 549 U.S. 1266 , 127 S. Ct. 1494 , 167 L.

2010Without such an articulation, the trial court is entirely ill-equipped to determine if the scientific evidence is reliable upon consideration of the various Porter factors.” Prentice v. Dalco Electric, Inc., 280 Conn. 336, 345 , 907 A.2d 1204 (2006), cert. denied, 549 U.S. 1266 , 127 S. Ct. 1494 , 167 L.