State v. Sellers

Summary

The Supreme Court of Connecticut reversed the defendant's murder conviction and ordered a new trial because the trial court abused its discretion in denying his request for a Porter hearing on the reliability of primer gunshot residue (pGSR) evidence, resting its denial solely on the methodology's well-established status without considering the defense's proffered ASTM standards and expert materials showing advances in the field. Applying the first illustrative scenario from its precedent, the court held that a trial court beginning from the premise that a methodology is well established must still consider new evidence to determine whether it sufficiently casts doubt on the methodology's continued reliability. The error was harmful because the state forensic laboratory examiner's testimony was the only evidence connecting a firearm to the defendant, and neither extensive cross-examination nor the remainder of the state's case supplied a fair assurance that the verdict was unaffected. The court did not reach the defendant's remaining appellate claims.