1. Introduction

In State v. Traynham, 0 Conn. 1 (July 22, 2025), the Connecticut Supreme Court revisited the perennial evidentiary question of when a hearsay statement that incriminates both the declarant and the accused may be admitted under the “statement against penal interest” exception, codified at §8-6(4) of the Connecticut Code of Evidence. The defendant, Rickey Traynham, was convicted of murder and related offenses surrounding a botched robbery in which both he and accomplice Jordan Rudel shot and killed a rideshare driver. On appeal Traynham argued that the trial court should have excluded Rudel’s confessions—made to Rudel’s girlfriend Adrianna Santiago and family friend Monique Jackson—because they were allegedly untrustworthy “blame-shifting” statements.

The case required the Court to refine the meaning of “trustworthiness” under §8-6(4), address whether minimizing language vitiates a statement’s self-inculpatory nature, and clarify that a distinction in the degree of blame—but not in the kind of offense—does not defeat admissibility. In doing so, the Court solidified and modestly extended prior decisions such as State v. Graham (2022) and State v. Rivera (2004).

2. Summary of the Judgment

The Supreme Court affirmed the trial court’s judgment, holding:

• Rudel’s statements were indisputably against his penal interest and thus fell within the hearsay exception of §8-6(4).
• The statements were sufficiently trustworthy under the three codified factors—timing/audience, corroboration, and degree of self-inculpation—even though Rudel attributed the fatal shots to Traynham.
• Any alleged “blame shifting” was only a difference in degree of culpability; Rudel still exposed himself to the same types of criminal liability (felony murder, robbery, firearms offenses).
• The Confrontation Clause was not implicated because the statements were non-testimonial, and the defense conceded that point.

Consequently, the evidentiary rulings were upheld and the convictions stand.

3. Analysis

3.1 Precedents Cited and Their Influence

• State v. Graham, 344 Conn. 825 (2022) – Provided the immediate doctrinal springboard. Graham held that a declarant’s felony-murder exposure renders a statement self-inculpatory even where the declarant minimizes his role. Traynham quotes Graham’s “degree vs. kind” language and extends it to a factual scenario with two distinct statements to two different confidants.
• State v. Rivera, 268 Conn. 351 (2004) – Recognized that admitting participation in an underlying felony suffices for penal-interest status, notwithstanding attempts to downplay the homicide itself. The Court reaffirmed that principle here.
• State v. Camacho, 282 Conn. 328 (2007) – Articulated that dual inculpatory statements are evaluated under the same §8-6(4) trustworthiness inquiry. Traynham followed Camacho’s framework.
• State v. Pierre, 277 Conn. 42 (2006) & State v. Lopez, 254 Conn. 309 (2000) – Earlier formulations of the three trustworthiness factors the Court applied.
• State v. Patel, 342 Conn. 445 (2022) – Endorsed a pragmatic weighing of consistencies vs. inconsistencies. The trial court in Traynham explicitly relied on Patel to discount peripheral discrepancies.

3.2 Legal Reasoning of the Court

Chief Justice Mullins, writing for a unanimous Court, marched through the §8-6(4) factors:

1. Timing and Audience. Statements made within days of the homicide, voluntarily and in confidence to a girlfriend (Santiago) and a quasi-family member (Jackson), were inherently reliable because (a) the lapse of time for contrivance was minimal and (b) no governmental pressure existed.
2. Corroboration. Independent evidence matched multiple details: the victim’s driver’s license, the Woodbridge park location, seven spent shell casings traceable to two guns, leg wounds, and rideshare context. Although Jackson’s recollection of a submerged car conflicted with physical evidence, the Court treated the inconsistency as peripheral under Patel.
3. Extent of Penal Interest. Rudel’s admissions exposed him to robbery, felony murder, and firearms charges. Whether his bullets were fatal is immaterial; the exposure was of the same kind as the charges against Traynham, satisfying the “risk of punishment” core of the exception.

3.3 Impact on Connecticut Evidence Law

The decision cements two notable clarifications:

• The “degree-versus-kind” distinction is now expressly part of Connecticut jurisprudence; minimization of personal conduct affects only weight, not admissibility, provided the declarant still faces liability for the same class of offenses.
• Trial courts may discount peripheral inconsistencies so long as core crime-scene details are corroborated. This pragmatic balancing endorses flexibility and discourages a hypertechnical exclusion of probative accomplice confessions.

Practically, prosecutors gain clearer guidance for admitting dual-inculpatory accomplice statements, while defense counsel must focus on impeachment rather than exclusion when only the “degree” of blame is contested. The ruling may also influence adoption of similar language in other jurisdictions that have not yet codified the three-factor test.

4. Complex Concepts Simplified

• Hearsay: An out-of-court statement offered to prove the truth of what it asserts. Generally inadmissible unless an exception applies.
• Statement Against Penal Interest §8-6(4): A hearsay exception for a declaration that subjects the speaker to possible criminal liability and is deemed reliable because people seldom make self-incriminating statements unless true.
• Dual Inculpatory Statement: A single statement that incriminates both the speaker and another person (usually the defendant). Evaluated under the same penal-interest framework.
• Trustworthiness Factors: (A) Proximity in time & relationship, (B) Corroborating evidence, (C) Extent of the declarant’s self-inculpation.
• Blame Shifting / Minimization: When a declarant admits involvement but tries to depict the co-actor as more culpable. Under Traynham, this does not defeat admissibility if the declarant still exposes himself to liability for the same type of crime.

5. Conclusion

State v. Traynham firmly establishes that, in Connecticut, the trustworthiness of a dual inculpatory statement hinges on kind rather than degree of inculpation. By endorsing a common-sense, totality-of-circumstances approach, the Court facilitated the rational admission of reliable accomplice confessions while respecting confrontation principles. Future litigants should expect courts to scrutinize timing, audience, corroboration, and the overall exposure the declarant faces—yet peripheral discrepancies or attempts at relative blame shifting will not by themselves bar admissibility. The ruling thus harmonizes Connecticut precedent and provides a clear, predictable standard for bench and bar.