State v. Joyner (2001)
In State v. Joyner, 255 Conn. 477, 494, 774 A.2d 927 (2001), the Court refused to adopt a per se rule against admitting into evidence the prior testimony of a witness who had been cross-examined by a conflicted counsel.
The Court observed that an independent evaluation of the adequacy of that cross-examination was not barred by a finding of a conflict of interest. Id.
The Court ordered the trial court to evaluate independently the reliability of the prior testimony to determine the admissibility of that witness' prior testimony in a subsequent trial. Id., 498.