STATE OF CONNECTICUT v. RICKEY TRAYNHAM, SC 20883

Judicial District of New Haven

Criminal; Hearsay Statement Against Penal Interest Under Code of Evidence § 8-6 (4); Whether Trial Court Improperly Admitted Hearsay Statements Into Evidence; Whether Alleged Evidentiary Error Was Harmless. The victim, Rondell Atkinson, worked for a rideshare service but also, personally drove people in exchange for cash. On the evening of June 7, 2021, the victim picked up Jordan Rudel and brought him to the defendant's house. When the defendant entered the car, he put a gun to the victim's head and ordered the victim to drive to a park in Woodbridge. In the park, the defendant ordered the victim out of the car, took his personal belongings, and, when the victim started to pray, the defendant shot the victim in the leg. The defendant then walked over to the victim and shot him multiple times before leaving with the victim's car. The next morning, a jogger found the victim's body and alerted the police. At that time, Rudel recounted the foregoing to his girlfriend, Adriana Santiago, who was on vacation in Florida with their children. Rudel showed Santiago a copy of the victim's license and told her to search for the victim's name, and she reported that the person was a homicide victim. When Santiago returned to Connecticut about a week later, she met with Rudel, and he explained that he and the defendant had intended only to rob the victim. A few days after the murder, Rudel also spoke with Monique Jackson, his father's longtime girlfriend, and told Jackson details of the killing as well. Prior to trial, the parties argued over whether to admit into evidence Rudel's out-of-court statements recounting the crime to Santiago and to Jackson. The state argued that the statements were admissible as statements against penal interest under § 8-6 (4) of the Code of Evidence, as Rudel had invoked his fifth amendment right against self-incrimination and therefore was unavailable to testify. The defendant argued that the statements should be suppressed because they were not trustworthy and because Rudel should be made available for cross examination. In response, the state contended that the hearsay statements were corroborated by forensic evidence, the ballistics report, and the fact that the victim's personal items were found with the defendant's girlfriend. The trial court allowed the statements into evidence, and, following a jury trial, the defendant was convicted of, inter alia, felony murder in violation of General Statutes § 53a-54c. He brings this appeal directly to the Supreme Court pursuant to General Statutes § 51-199 (b) (3), and the defendant's sole claim is that the trial court erred in admitting into evidence pursuant to § 8-6 (4) Rudel's hearsay statements to Santiago and Jackson. He argues that the factors enumerated in that section weigh in favor of excluding the statements because there were material differences between the statements and also because the statements were inconsistent with the other evidence. Moreover, the defendant argues that Rudel's statements shifted blame and minimized his role in the crimes, which the trial court failed to consider, and, as a result, the court erred by finding that the statements were sufficiently reliable so as to be admitted into evidence. In response, the state contends that the trial court did not abuse its discretion by admitting Rudel's hearsay statements into evidence, as they were corroborated by "overwhelming evidence," including, inter alia, the location of the victim's body, the ballistics evidence, the fact that the victim's personal items were recovered from the defendant's girlfriend, and the recovery of the defendant's DNA and fingerprints from the victim's vehicle. The state finally argues that, even if the evidence was improperly admitted, any error was harmless "because there was significant corroborating evidence and the state's case was overwhelming."