State v. Wilson (1986)

In State v. Wilson, 199 Conn. 417, 449, 513 A.2d 620 (1986), the defendant successfully appealed from his manslaughter conviction concerning the death of one of his girlfriend's children due to child abuse. In that case, the state presented voluminous evidence that the victim and her sister had had many prior injuries indicative of child abuse. The Wilson defendant objected to the admission of the evidence, as there was no evidence that he was responsible for the children's injuries. Id., 448. In reversing the judgment of conviction, our Supreme Court stated that "unless circumstances indicate otherwise, evidence that the defendant has intentionally abused the child victim in the past is probative on the issue of his intent to cause injury with respect to the crime charged. However, before such evidence can have any probative value, there must be a preliminary showing sufficient to support a jury finding that the defendant, in fact, caused the prior injury." Id., 449.