## Facts

- Bruce R. Christian, Jr. spent an evening drinking with Victoria Ryan and her roommate, Alexander Imperatrice, first at a bar in Massachusetts and later at Ryan’s home in Enfield, Connecticut.
- Near midnight, Christian and Ryan left Ryan’s home together in Ryan’s car; soon after, the car crashed in a one-vehicle accident that killed Ryan.
- The key factual dispute at trial was whether Christian or Ryan was driving at the time of the crash; Christian claimed Ryan was the driver.
- While hospitalized, Christian spoke privately with his wife, Joan Christian, and allegedly admitted he had been driving, accompanied by gestures suggesting steering.
- By trial, the marriage was deteriorating and divorce proceedings were underway.
- The trial court admitted Joan’s testimony about the hospital-room admission, ruling the marital communications privilege did not apply due to the broken relationship.
- The state also introduced testimony from three other witnesses that Christian admitted he was the driver.
- Christian was convicted of second-degree manslaughter with a motor vehicle, operating under the influence, and reckless driving.

## Issues

1. Whether a confidential spousal communication made during a valid marriage remains protected by the marital communications privilege despite later marital breakdown.
2. Whether the trial court improperly restricted the defense from presenting evidence of a spouse-witness’s motive to testify falsely (bias).
3. Whether emergency medical “run sheets” were admissible either as prior inconsistent statements to impeach emergency personnel or as business records.

## Decision

- The court held the trial court erred by admitting Joan Christian’s testimony about the private hospital-room communication because the marital communications privilege applied.
- The court held the trial court erred by excluding defense evidence offered to show Joan’s potential bias or motive to testify falsely.
- The court concluded both errors were harmless because Joan’s testimony on the identity of the driver was cumulative of multiple independent admissions by Christian to other witnesses.
- The court held the emergency medical “run sheets” were properly excluded because they did not qualify as admissible prior inconsistent statements and were not shown admissible as business records.
- The judgment of conviction was affirmed.

## Legal Principles

- The marital communications privilege protects confidential communications made during a valid marriage when made in confidence; later marital discord or dissolution does not negate the privilege for communications already made.
- A defendant is generally entitled to present relevant evidence of a witness’s bias or motive to testify falsely; undue restrictions may raise confrontation concerns.
- Erroneous evidentiary rulings do not require reversal when the state shows the errors did not materially affect the verdict, including when the challenged evidence is cumulative of strong independent proof.
- Prior inconsistent statement impeachment requires a meaningful inconsistency between the prior statement and trial testimony.
- Business-records admission requires an adequate foundation satisfying the elements of the hearsay exception; absent that showing, exclusion is within the trial court’s discretion.

## Conclusion

The Connecticut Supreme Court affirmed Christian’s convictions, holding that confidential spousal communications remained privileged and that bias-impeachment evidence was improperly excluded, but concluding both errors were harmless in light of other admissions identifying Christian as the driver; the court also upheld exclusion of emergency medical run sheets.


State v. Christian, 267 Conn. 710, 841 A.2d 1158 (Conn. 2004)