State v. Moody
In State v. Moody, 214 Conn. 616, 573 A.2d 716 (1990), the defendant argued that the trial court incorrectly permitted the state's serologist to testify that a stain on one of the soles of the defendant's shoes showed a positive result for the "presumptive test for blood." The "presumptive test for blood" is "a preliminary screening test that determines whether the actual test for blood should be administered." Id., at 627.
The Court reversed the defendant's murder conviction after concluding that the trial court had abused its discretion in admitting into evidence testimony regarding the results of a presumptive test for blood performed on a stain found on the sole of the defendant's shoe. State v. Moody, supra, 214 Conn. at 628.
The defendant sought unsuccessfully to preclude a state's witness from testifying that a stain on the sole of his shoe passed a presumptive test for blood. Id.
Over the defendant's objection, the state's witness testified as to the positive test results and further explained that they meant that the stain could have been human blood, animal blood or something other than blood. 214 Conn. at 627-28.
The Court concluded that "the result of the 'presumptive test for blood' had no probative value whatsoever" because the test "did nothing toward establishing the likelihood of the presence of human blood on the sole of the defendant's shoe." Id. at 628.
The Supreme Court held that the trial court had abused its discretion in denying the defendant's motion in limine because the test result was irrelevant. Id.
The Court noted in Moody, "the first test of the admissibility of any evidence is whether it is relevant. . . . Evidence is relevant only when it tends to establish the existence of a material fact or to corroborate other direct evidence in the case. . . . One fact is relevant to another fact whenever, according to the common course of events, the existence of the one, taken alone or in connection with other facts, renders the existence of the other either certain or more probable . . . ." Id.
In Moody, the witness' testimony was held to be inadmissible because it had no probative value and was therefore irrelevant. Id.
In Moody, because the stain was too small, the determinative test for blood could not be performed. Id., at 628.
The Court found that the test result was "entirely irrelevant" and had "no probative value because it did nothing toward establishing the likelihood of the presence of human blood on the sole of the defendant's shoe." Id.