State v. Holloman
In State v. Holloman, 20 Conn. App. 521, 568 A.2d 1052 (Conn. App. 1990), a robbery case, the defendant offered evidence that his alleged accomplice, who owned the get-away car used in the crime, was friends with and lived in the same building as a third party whose physical description matched the description of the robber given by eyewitnesses to the crime, that the car could be operated without a key, that the accomplice was aware that people used his car without permission, and that the accomplice had left his car at his residence and not driven it on the day of the robbery. Holloman, 568 A.2d at 1057.
The trial court excluded the third party's physical description from evidence. The appellate court expressed the same rule applied by the Idaho Supreme Court in State v. Larsen, stating that evidence of third-party culpability would be allowed only if it directly connected the third party with the crime.
The court concluded that such a connection had not been made with the proffered evidence, and consequently the physical description and residence of the third party were inadmissible. Id.