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Hilton v. Commissioner of Correction

2026-06-30No. SC21106

Summary

Holding. The Supreme Court of Connecticut affirmed the judgment of the Appellate Court, holding that the habeas court correctly applied the legal standard for assessing expert credibility under Strickland v. Washington and did not err by declining to apply a different standard from Lapointe v. Commissioner of Correction, as Lapointe addressed only an exceptional circumstance involving factually unsupported credibility findings in a weak evidence case, and the habeas court's credibility determinations here were supported by the record.

James Hilton was convicted of murder in 2000 for shooting William Rodriguez. At trial, a medical examiner testified that the fatal wound was consistent with a contact shot (gun barrel touching skin). Hilton claimed his trial counsel failed to adequately challenge this testimony and present contrary expert evidence. After his first habeas petition was denied, Hilton filed a second habeas petition presenting new expert testimony from a forensic pathologist who disagreed with the contact-wound conclusion and opined the victim was shot from at least twenty-four inches away.

The habeas court rejected the new expert's testimony as not credible, noting it failed to account for specific wound characteristics (such as a stellate tear and blowback laceration) that other experts had identified. The court also emphasized the state's overwhelming evidence of guilt, including two eyewitnesses who identified Hilton as the shooter and no corroborating witnesses to his account. Both the habeas court and the Appellate Court denied relief.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

  • Whether Lapointe v. Commissioner of Correction altered the legal standard for habeas courts assessing expert witness credibility in ineffective assistance of counsel claims
  • Whether trial counsel rendered ineffective assistance by failing to adequately cross-examine the state's medical examiner and present contradictory expert testimony
  • Whether new expert testimony about the distance of the fatal gunshot was credible and would have created a reasonable probability of a different trial outcome

Procedural posture

Hilton filed a second habeas petition after his first habeas petition was denied; the habeas court denied the second petition, the Appellate Court affirmed, and the Supreme Court of Connecticut granted certification to review the habeas court's application of legal standards for evaluating expert credibility.

Authorities cited

Opinion

majority opinion

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Hilton v. Commissioner of Correction

JAMES HILTON v. COMMISSIONER

OF CORRECTION

(SC 21106)

Mullins, C. J., and McDonald, D’Auria,

Ecker, Dannehy and Bright, Js.

Syllabus

The petitioner, who had been convicted of murder, among other crimes, in connection with the shooting death of the victim, filed a second petition for a writ of habeas corpus, claiming that his trial counsel and first habeas counsel had rendered ineffective assistance by failing to adequately investigate the opinion of K, the associate medical examiner who had performed the victim’s autopsy. At the petitioner’s criminal trial, a key issue was whether the fatal shot that caused the victim’s death had been discharged at close range or from a distance, and K opined during the criminal trial that the barrel of the gun that was used to shoot the victim had been touching the victim’s skin when the gun was fired. At the petitioner’s first habeas trial, his counsel presented the expert testimony of C, the chief medical examiner, and D, a forensic scientist, in support of the petitioner’s claim that trial counsel had failed to adequately cross-examine K and to present expert testimony on the petitioner’s behalf. The first habeas court rejected the petitioner’s claim and denied the first habeas petition. At his second habeas trial, the petitioner presented the testimony of W, an expert in forensic pathology, who disagreed with K’s conclusion that the victim’s fatal wound was a contact wound and testified that the victim had been shot from a distance. The second habeas court, after reviewing the prior testimony of K, C and D, and weighing W’s testimony, found that neither W nor his conclusion about the shot distance were credible and rendered judgment denying the second habeas petition. The petitioner, on the partial granting of certification, appealed to the Appellate Court, which dismissed in part the petitioner’s appeal and affirmed the second habeas court’s judgment. In so doing, the Appellate Court rejected the petitioner’s claim that the second habeas court had failed to apply the proper standard for evaluating the credibility of expert witnesses, purportedly set forth in Lapointe v. Commissioner of Correction (316 Conn. 225). On the granting of certification, the petitioner appealed to this court. Held: The Appellate Court correctly determined that the second habeas court had applied the correct legal standard for evaluating the credibility of expert witnesses, this court having concluded that Lapointe did not vary the standard, set forth in Strickland v. Washington (466 U.S. 668), that is applicable to ineffective assistance claims or alter how a habeas court is to assess the credibility of experts.

Lapointe did not prescribe a different legal standard for a habeas court’s assessment of the credibility of expert witnesses; rather, Lapointe involved an unusual circumstance in which the habeas court made clearly erroneous credibility findings that the record did not support, and the prejudicial effect of that error was evident in Lapointe because the evidence against the petitioner in that case was weak.

Hilton v. Commissioner of Correction

In the present case, the second habeas court was required make a predictive assessment about whether there was a reasonable probability that the petitioner would have prevailed if his first habeas counsel had called W to testify, and, in making that predictive assessment, the second habeas court properly weighed W’s expert opinion in light of W’s methodology and the court’s own firsthand observations of the persuasiveness of W’s testimony.

Accordingly, the second habeas court applied the proper legal standard when it concluded that the outcome of the petitioner’s criminal trial would not have been different if W had testified because W’s testimony would not have persuaded the criminal trial jury insofar as W failed to account for certain other features of the fatal wound about which C and D had testified, and W’s testimony would not have overcome the state’s overwhelming eyewitness and forensic testimony, as well as evidence of the petitioner’s motive.

Moreover, this court agreed with the Appellate Court that the evidence of the petitioner’s guilt in this case was not weak insofar as there were two eyewitnesses who gave statements identifying the petitioner as the shooter and no witnesses who corroborated the petitioner’s claim that other individuals were responsible for the shooting, and the Appellate Court had previously noted the overwhelming nature of the state’s case against the petitioner, both in the petitioner’s direct appeal and also in his appeal from the first habeas court’s judgment.

Argued March 6—officially released June 30, 2026

Procedural History

Amended petition for a writ of habeas corpus, brought

to the Superior Court in the judicial district of Tolland

and tried to the court, Klatt, J.; judgment denying the

petition, from which the petitioner, on the granting of

partial certification, appealed to the Appellate Court,

Alvord, Moll and Clark, Js., which dismissed the appeal

in part and affirmed the habeas court’s judgment, and

the petitioner, on the granting of certification, appealed to this court. Affirmed.

Alexander T. Taubes, for the appellant (petitioner).

Laurie N. Feldman, assistant state’s attorney, with

whom, on the brief, were John P. Doyle, Jr., state’s

attorney, and Craig P. Nowak, supervisory assistant

state’s attorney, for the appellee (respondent).

Robert J. Meredith, Desmond Ryan and M. Chris

Fabricant, pro hac vice, filed a brief for the Innocence

Project, Inc., et al., as amici curiae.

Hilton v. Commissioner of Correction

Opinion

D’AURIA, J. In this certified appeal, we consider

whether the Appellate Court correctly determined that

the habeas court had applied the correct legal standard

in denying the second petition for a writ of habeas corpus filed by the petitioner, James Hilton. The petitioner

claims that the habeas court failed to apply the standard

for evaluating the credibility of expert witnesses that this court articulated in Lapointe v. Commissioner of Correction, 316 Conn. 225, 112 A.3d 1 (2015). We disagree

and affirm the Appellate Court’s judgment.

The Appellate Court’s opinion aptly recites the facts

and procedural history required to resolve this appeal;

see Hilton v. Commissioner of Correction, 225 Conn.

App. 309, 312–23, 315 A.3d 1135 (2024); which we summarize along with other undisputed facts in the record.

In July, 2000, the victim, William Rodriguez, was shot

and killed on Truman Street in New Haven. The police

found the victim’s body on the sidewalk, surrounded

by a crowd of people. An autopsy later revealed that the

victim died from a single gunshot at close range to the

left side of his head.

A drug turf war in the Truman Street area between the

petitioner and the victim’s associates had been ongoing,

including two altercations in the days leading up to the

shooting. The victim had recently moved into an apartment on Truman Street. One eyewitness to the shooting,

Sherice Mills, saw the petitioner approach the victim as

the victim was making a drug sale to someone in a car.

Mills testified that she had heard the petitioner state

that he was “about to kill [the victim]” and observed

the petitioner shoot the victim in the head. (Internal

quotation marks omitted.) Id., 313. According to Mills,

the petitioner fell to the ground with the victim, and the petitioner “kept holding [the victim’s] head, saying he

didn’t mean to do it and [telling] somebody to call the

police.” (Internal quotation marks omitted.) Id. Mills

later identified the petitioner as the shooter from an array of photographs. A second eyewitness, Simone Williams,

Hilton v. Commissioner of Correction

corroborated Mills’ account and added that the petitioner

had approached the victim from behind and stated: “You

ain’t from around here, son,” and, “[y]ou need to move

from around here, son,” and then took a gun from behind

his back and shot the victim. (Internal quotation marks

omitted.) Id., 314. Williams positively identified the

petitioner in a photographic array and did so again at

trial. A third eyewitness, Toisann Henderson, saw the

petitioner shoot the victim and ran into the victim’s

apartment to tell the victim’s girlfriend, Cora Moore.

The petitioner voluntarily went to the police station

and informed detectives that he had been sitting on his

porch when he heard a commotion and went to see what

was happening. He said that a third man had drawn a

gun, that the petitioner had grappled for the gun, and

“it went bashing across [the victim’s] head.” (Internal

quotation marks omitted.) Id., 315. At trial, the petitioner described how several seconds after he had fought

with the third man, a fourth man shot the victim and ran

away. The petitioner testified that, immediately after

the gunshot, he applied pressure to the victim’s wound

to stop the bleeding and then left to make sure someone

had called an ambulance. He explained that he left the

scene after people in the crowd began to tell the police

that he was the shooter. Although the petitioner had

his bloodied clothes washed, the state discovered a drop

of blood on his boxer shorts that matched the victim’s

blood type and DNA.

The state charged the petitioner with murder, criminal

possession of a pistol or revolver and carrying a pistol

or revolver without a permit. One of the key issues at

the petitioner’s criminal trial was the distance the fatal gunshot had traveled. The state contended that the petitioner had shot the victim at close range; the petitioner

maintained that someone else had fired the gunshot from

a distance. The state presented the testimony of Arkady

Katsnelson, an associate medical examiner in the Office of the Chief Medical Examiner, who performed the victim’s

autopsy. Katsnelson testified that, because “there was

Hilton v. Commissioner of Correction

no evidence of soot or gunpowder,” the victim’s gunshot

wound case resembled either a “long distance” wound

resulting from a gun generally being “more than three

feet” away, or a contact wound caused by “the barrel of

the gun . . . touching the skin, touching the body . . . .” (Internal quotation marks omitted.) Id., 316 and n.2.

Katsnelson’s expert opinion was that “[t]his gunshot

wound, it is not typical [of] a gunshot wound which was

created from a long distance because a gunshot wound

from a distance will be a round shape, and the round shape . . . and . . . size of the wound will be slightly bigger than the size of the bullet.” (Internal quotation marks omitted.) Id., 316. Katsnelson noted that a contact wound is

larger and does not have gunpowder residue around the

wound because the gun’s muzzle directs gases and residue

through the skin. Katsnelson’s conclusion was that the

victim’s wound was consistent with a contact gunshot

wound of entrance, meaning the barrel of the gun was

touching the skin when the gun was discharged. The

petitioner’s defense counsel cross-examined Katsnelson

but did not present his own expert on the nature of the

victim’s wound to counter Katsnelson’s opinion.

A jury found the petitioner guilty of murder, criminal

possession of a pistol or revolver and carrying a pistol or revolver without a permit. The trial court imposed a total effective sentence of sixty-five years of imprisonment.

The Appellate Court rejected the petitioner’s prosecutorial impropriety claim and affirmed the petitioner’s

conviction on direct appeal. See State v. Hilton, 79 Conn. App. 155, 170, 829 A.2d 890 (2003).

The petitioner commenced his first habeas action,

in which he alleged that his criminal trial counsel had

rendered ineffective assistance by failing to adequately

cross-examine Katsnelson regarding the nature of the

victim’s fatal wound and failing to present his own expert testimony regarding the wound. At the first habeas trial,

the petitioner’s counsel sought to undercut Katsnelson’s

autopsy report and conclusions by presenting the expert

testimony of Harold Wayne Carver II, the state’s chief

Hilton v. Commissioner of Correction

medical examiner, and Peter DeForest, who held a doctorate degree in forensic science.

Carver testified that there was a sufficient basis from

the autopsy photographs and report to conclude that the

wound had resulted from a contact shot based on the large

size and abnormal shape of the wound. He noted that one

phenomenon that is a “very, very strong criteri[on]” of a

contact wound is a blowback laceration that occurs when

the force is great enough to make the skin explode toward

the muzzle. He explained that blowback lacerations can

have serrated edges, also referred to as “stellate” because they are starlike, which can extend symmetrically in all

directions around the wound. Carver also opined that,

in addition to the large size and irregular shape of the

wound, there was one stellate arm present at the irregular perforation, indicating a blowback laceration caused by

a contact wound.

DeForest testified that the wound was “ambiguous,”

and he could not conclude with certainty whether the

wound resulted from a contact shot or from a shot from

a distance. DeForest noted that the oval shape of the

wound could have been caused by a destabilized bullet

that struck the skin sideways. “Nevertheless, [DeForest]

acknowledged that a bullet striking the skin at an angle

can cause an oval wound. . . . In [DeForest’s] assessment, this was either a contact wound or a distance wound

where the bullet had become destabilized.” (Citation

omitted.)

The habeas court denied the petitioner’s first habeas

petition. The court determined that defense counsel had

not rendered deficient performance because the scope

of the cross-examination of Katsnelson reflected a reasonable trial strategy. The habeas court also concluded

that the petitioner had failed to prove prejudice because

DeForest’s opinion that the wound was ambiguous did not

contradict Katsnelson’s testimony that it was a contact

wound. The Appellate Court affirmed the habeas court’s

judgment; Hilton v. Commissioner of Correction, 161

Conn. App. 58, 85, 127 A.3d 1011 (2015); and we denied

Hilton v. Commissioner of Correction

the petitioner’s petition for certification to appeal. Hilton v. Commissioner of Correction, 320 Conn. 921, 132

A.3d 1095 (2016).

The petitioner then filed his second habeas petition,

which is at issue in this appeal. He alleged that his first habeas counsel and criminal trial counsel had rendered

ineffective assistance by failing to adequately investigate Katsnelson’s opinion. He further alleged that,

although his first habeas counsel had presented two

experts (DeForest and Carver), both counsel failed to

present expert testimony from a forensic pathologist to

undercut Katsnelson’s opinion. Hilton v. Commissioner

of Correction, supra, 225 Conn. App. 320–21. In support

of this claim, the petitioner presented the testimony

and report of his new forensic pathology expert, Cyril

H. Wecht.

Wecht testified that he had reviewed, among other

things, Katsnelson’s autopsy report and photographs,

Katsnelson’s testimony from the criminal trial, a police

report, the petitioner’s posttrial brief from his first

habeas trial, and a field report from a private investigation service. Wecht acknowledged that he had not

reviewed the transcripts from the first habeas trial,

including the testimony of Carver that the wound had

blowback stellate. Wecht disagreed with Katsnelson’s

opinion and offered his own opinion that the victim’s

gunshot wound was not a contact wound but, instead,

resulted from a bullet fired from a gun held at least

twenty-four inches from the victim. He explained that he

arrived at his conclusion because there was no gunpowder

residue or stippling, which is the term used to describe

skin abrasions resulting from burning gunpowder particles. Wecht agreed that the wound was oval and not

round, indicated that he did not see any stellate tears on the wound, and could rule out a “loose” contact gunshot

wound in which gunpowder residue goes into the wound

or onto bone, but also onto skin.

The habeas court denied the petitioner’s second habeas

petition. The court reviewed in detail the prior testimony

Hilton v. Commissioner of Correction

of Katsnelson, DeForest, and Carver with respect to the

distance a gun would have had to be from the victim to

create the type of wound that the victim sustained. The

court observed that “[t]hree of the four experts found

that there were indicia of a contact wound. Only . . .

Wecht completely ruled out the possibility of a contact

wound.” The court went on to state that it did “not find . . . Wecht’s assessment to be credible, especially because

he did not review . . . Carver’s testimony from the first

habeas trial. . . . Carver observed a stellate tear and evidence of a blowback laceration. Additionally . . . Wecht

did not provide any explanation for the causes of the

oval wound. Nor did . . . Wecht’s evaluation address

the potential effects of the victim being kept alive for a day or more so that organs could be harvested from his

cleaned and disinfected body, the blood from the wound

washing away gunshot residue, or the beginnings of the

healing process making residue in the wound difficult to

detect. The more credible evidence establishes that the

shot that killed the victim was a contact shot. Because

the court does not find . . . Wecht’s conclusion that the

shot could not have been fired from less than twenty-four

inches to be credible, [the petitioner’s] claims premised

thereon must fail.”

The habeas court concluded that the petitioner’s

trial counsel did not perform deficiently by failing to

adequately cross-examine Katsnelson and that first

habeas counsel did not perform deficiently by calling

Carver, a forensic pathologist, “whose experience and

credentials are on par with, if not superior, to [Wecht].” The habeas court further found that the petitioner had

failed to establish prejudice because the court was not

persuaded that Wecht’s testimony would have made a

difference to the outcome of the petitioner’s criminal

trial because Wecht was not credible, and the state had

abundant and overwhelming evidence of identification

and motive, which supported the forensic testimony at

the petitioner’s criminal trial.

The petitioner filed a petition for certification to appeal with the habeas court. Two of the grounds he advanced

Hilton v. Commissioner of Correction

challenged whether the habeas court had failed to apply

the correct legal standard under Lapointe v. Commissioner of Correction, supra, 316 Conn. 272–73, to determine that [Wecht’s conclusion] was not credible. The

habeas court denied the petition to appeal as to this issue, holding that, “[c]ontrary to the petitioner’s argument

in the petition for certification to appeal, Lapointe . . . does not preclude a habeas court from determining that

an expert witness and their conclusion are not credible.

Nor does Lapointe establish a standard that a petitioner

is entitled to a new trial by presenting an expert who

is of ‘sufficient import and credibility.’ Such a vague

standard could necessitate a new criminal trial in nearly

all postconviction habeas proceedings involving expert

witnesses. A habeas court’s credibility assessments and

how they impact the prejudice prong of the ineffective

assistance of counsel standard would be rendered meaningless if a habeas court had to grant a new trial upon the presentation of expert testimony that was ‘of sufficient

import and credibility.’ ” The habeas court further elaborated on its finding about Wecht’s credibility, stating

that it found “Wecht’s conclusion that the shot could not

have been fired from less than twenty-four inches to be

not credible. The court did not find . . . Wecht credible

based on the totality of all evidence from the criminal,

prior habeas, and current habeas trials. . . . Wecht did

not review all relevant evidence, and his opinion was

contradicted by the factual findings regarding the shape

of the wound, stellate tearing, and evidence of a blowback laceration. It is this lack of foundation supporting . . . Wecht’s conclusion about the shot distance that caused

the court to find him not credible as an expert witness.”

(Emphasis omitted.)

The Appellate Court affirmed the habeas court’s

judgment. See Hilton v. Commissioner of Correction,

supra, 225 Conn. App. 341. In particular, it rejected the

petitioner’s claim that the habeas court had applied an

incorrect legal standard in assessing witness credibility

by failing to follow the prescriptions of Lapointe. See

id., 333. It held that the habeas court had applied the

Hilton v. Commissioner of Correction

correct, well established standard because Lapointe was

factually and legally distinguishable. See id., 337–38.

Factually, the court held that the evidence of the petitioner’s guilt was overwhelming in the present case,

whereas the evidence against the petitioner in Lapointe

was weak and founded on “highly questionable admissions.” (Internal quotation marks omitted.) Id., 337. The

Appellate Court further held that Lapointe involved a

Brady1 claim, whereas the petitioner in the present case

founded his claim on Strickland.2 See id., 331, 337–40.

We granted certification to decide whether “the Appellate Court correctly conclude[d] that the habeas court

had properly declined to apply the standard in Lapointe

. . . for evaluating an expert witness’ credibility . . . .” (Citation omitted.) Hilton v. Commissioner of Correction, 351 Conn. 916, 332 A.3d 293 (2025).

“A defendant seeking habeas relief for ineffective

representation must prove two elements. First, the defendant must show that counsel’s performance was deficient.

This requires [a] showing that counsel made errors so

serious that counsel was not functioning as the counsel

guaranteed the defendant by the [s]ixth [a]mendment.

Second, the defendant must show that the deficient performance prejudiced the defense.” (Internal quotation

marks omitted.) Maia v. Commissioner of Correction,

347 Conn. 449, 460, 298 A.3d 588 (2023). To prevail on

a second habeas petition, a petitioner is faced with the

task of establishing that (1) his first habeas counsel was ineffective, and (2) his trial counsel was ineffective. See, e.g., Kaddah v. Commissioner of Correction, 324 Conn.

548, 562, 153 A.3d 1233 (2017).

In determining whether a petitioner has met his burden

of establishing prejudice, “[t]he principal question . . . is whether there is a reasonable probability that, absent

the errors, the [fact finder] would have had a reasonable

doubt respecting guilt. . . . A reasonable probability

1

Brady v. Maryland, 373 U.S. 83, 83 S. Ct. 1194, 10 L. Ed. 2d 215 (1963).

2

See Strickland v. Washington, 466 U.S. 668, 104 S. Ct. 2052, 80 L. Ed. 2d 674 (1984).

Hilton v. Commissioner of Correction

is a probability sufficient to undermine confidence in

the outcome. . . . In making a prejudice determination,

habeas courts must consider the totality of the evidence

before the judge or jury. . . . Some factual findings will be unaffected by the errors, and factual findings that were

affected will have been affected in different ways. . . .

Indeed, [s]ome errors will have had a pervasive effect on

the inferences to be drawn from the evidence, altering

the entire evidentiary picture, whereas some will have

had an isolated, trivial effect. . . . [A] verdict or conclusion only weakly supported by the record is more likely to have been affected by errors than one with overwhelming

record support.” (Citations omitted; internal quotation

marks omitted.) Grant v. Commissioner of Correction,

354 Conn. 30, 41–42, 348 A.3d 463 (2026).

In assessing whether a petitioner has met his burden,

a habeas court, as the finder of fact, must assess whether to believe all, none, or some of the testimony presented.

See, e.g., Barlow v. Commissioner of Correction, 343

Conn. 347, 367, 273 A.3d 680 (2022). The habeas court

“is free to juxtapose conflicting versions of events and

determine which is more credible.” (Internal quotation

marks omitted.) Echeverria v. Commissioner of Correction, 193 Conn. App. 1, 15 n.6, 218 A.3d 1116, cert.

denied, 333 Conn. 947, 219 A.3d 376 (2019); see also

Bowens v. Commissioner of Correction, 333 Conn. 502,

523, 217 A.3d 609 (2019).

An appellate court “does not retry the case or evaluate

the credibility of the witnesses. . . . Rather, [the reviewing court] must defer to the [habeas court’s] assessment

of the credibility of the witnesses based on its firsthand observation of their conduct, demeanor and attitude.”

(Internal quotation marks omitted.) Taylor v. Commissioner of Correction, 324 Conn. 631, 643, 153 A.3d 1264

(2017); accord Sanchez v. Commissioner of Correction,

314 Conn. 585, 604, 103 A.3d 954 (2014). A habeas

court’s pure credibility determination is unassailable,

and we will not disturb it on appeal. See Breton v. Commissioner of Correction, 325 Conn. 640, 694, 159 A.3d

Hilton v. Commissioner of Correction

1112 (2017); Orcutt v. Commissioner of Correction, 284

Conn. 724, 741, 937 A.2d 656 (2007). “Because it is the

[habeas] court’s function to weigh the evidence and determine credibility, we give great deference to its findings. . . . In reviewing factual findings, [w]e do not examine

the record to determine whether the [court] could have

reached a conclusion other than the one reached. . . .

Instead, we make every reasonable presumption . . . in

favor of the [habeas] court’s ruling.” (Internal quotation marks omitted.) Barlow v. Commissioner of Correction, supra, 343 Conn. 357–58. Thus, the habeas judge’s

credibility determinations and findings are entitled to

deference from this court and cannot be disregarded

unless they are clearly erroneous. See, e.g., Small v.

Commissioner of Correction, 286 Conn. 707, 716, 946

A.2d 1203, cert. denied sub nom. Small v. Lantz, 555

U.S. 975, 129 S. Ct. 481, 172 L. Ed. 2d 336 (2008).

In Lapointe, this court recognized an “exceptional

factual and procedural scenario” in which we held that

the habeas court’s credibility assessment of expert witnesses was clearly erroneous. Lapointe v. Commissioner

of Correction, supra, 316 Conn. 272–73.3 In that case,

the petitioner was convicted of capital felony and other

offenses for the rape and murder of an elderly woman

and the arson of her apartment to destroy the evidence.

Id., 229. After an unsuccessful direct appeal and first

3

In the decade since Lapointe, this court has not encountered another factual and procedural scenario in which it was appropriate to review with elevated scrutiny a habeas court’s credibility assessment of an expert. Instead, we have twice rejected the application of Lapointe review. See, e.g., In re Jewelyette M., 351 Conn. 511, 562 n.32, 332 A.3d 207 (2025) (trial court’s finding of “ ‘no credible evidence’ ” was not limited circumstance in which Lapointe applies (emphasis in original)); State v. Campbell, 328 Conn. 444, 486–88 and n.13, 180 A.3d 882 (2018) (trial court’s discrediting of defendant’s experts was not subject to Lapointe review). And we have relied on Lapointe for the established rule that this court must defer to a habeas court’s credibility assessments. See, e.g., Horn v. Commissioner of Correction, 321 Conn. 767, 783 n.12, 138 A.3d 908 (2016) (quoting Lapointe for proposition that “ ‘we ordinarily accord deference to credibility determinations that are made on the basis of [the] firsthand observation of [a witness’] conduct, demeanor and attitude’ ”).

Hilton v. Commissioner of Correction

habeas petition, the petitioner filed a second habeas petition alleging that his first habeas counsel had rendered

ineffective assistance by failing to pursue a claim that the state violated Brady by withholding a police note regarding the amount of time that the fire had burned inside

the apartment before it was discovered. Id., 230–31. The

petitioner claimed that the note would have established

a complete alibi defense because it purported to identify

the time frame within which the fire was set, for which

the petitioner had witnesses testify that he was home.

Id., 231. At the second habeas trial, the petitioner and

the respondent presented conflicting expert testimony

as to the length of time that the fire had burned in the

victim’s apartment. Id., 232–33. The habeas court denied

the petitioner’s claim because it found that the testimony of the respondent’s expert was far more persuasive than the testimony of the petitioner’s experts and

that it was not reasonably probable that, if the jury at

the petitioner’s criminal trial had heard the testimony

of the petitioner’s experts, it would have credited that

testimony and reached a different result. See id., 233.

This court in Lapointe did not substitute its own credibility determination for that of the habeas court but,

instead, concluded that the underlying factual findings

on which the habeas court relied to discredit the petitioner’s experts were clearly erroneous because they were

unsupported by the record. See id., 273. This court held

that it was “not bound” by the habeas court’s “appraisal

of the scientific underpinnings of the parties’ expert

testimony”; id., 261; because the habeas court’s “critique” of the petitioner’s experts was “comprised of

factually unfounded assertions.” Id., 277. For instance,

we reasoned that the habeas court had erroneously (1)

characterized the testimony of the petitioner’s experts as a “high energy fire” when they in fact did not state that

and had opined that it was a “low energy fire”; id., 278;

(2) stated that the respondent’s expert provided a lower

peak temperature when his testimony was the opposite;

id.; (3) considered the petitioner’s experts’ maximum

fire temperature as “ ‘wildly exaggerated’ ” when the

Hilton v. Commissioner of Correction

respondent’s expert never disputed that testimony; id.,

279; and (4) determined that the petitioner’s experts’ fire burn time was contradicted by the historical and physical

evidence marshaled by the respondent’s expert when a

review of the criminal trial record showed the converse.

Id., 287–88. In light of these clearly erroneous findings

and taking “due account of the fact that the state’s case

against the petitioner was relatively weak, founded as it

was on highly questionable admissions” by the petitioner;

id., 261; whose cognitive and motor skills were impaired

as a result of Dandy-Walker syndrome, causing him to

be “slow-witted, easily confused, childlike and gullible”; id., 240; this court determined that the petitioner was

entitled to a new criminal trial. Id., 349.

In the present case, the question the petitioner raised

in his petitions for certification to the habeas court and this court, and the question as to which we granted certification, is whether the habeas court had erred by failing to apply Lapointe in assessing Wecht’s credibility. The

parties do not dispute that the habeas court did not cite, apply, or use a standard articulated by Lapointe. We

conclude, however, that the habeas court did not err in

not applying Lapointe because our decision in that case

did not alter a habeas court’s analysis of a claim brought pursuant to Strickland v. Washington, 466 U.S. 668,

687, 104 S. Ct. 2052, 80 L. Ed. 2d 674 (1984), or how it

is to make credibility assessments of experts. Lapointe

represented an unusual circumstance in which this court

concluded that the habeas court made erroneous credibility findings that the record did not support in a case in which the prejudicial effect of that error was evident

because the evidence against the petitioner was weak.

What made Lapointe “extraordinary” was the searching nature of the appellate review we found necessary to

review for clear error a habeas court’s credibility determination of an expert witness; our analysis did not change

the legal standard the trial court must apply in making

credibility determinations in the first instance. Because

Lapointe in fact did not prescribe a different legal standard to be applied by the habeas court, the habeas court

Hilton v. Commissioner of Correction

in the present case did not err when it applied the usual

standard set forth in Strickland.

Our well established standard—both before and after

Lapointe—required the habeas court to make the predictive judgment as to whether there is a reasonable

probability that the petitioner would have prevailed if

the petitioner’s first habeas counsel had called Wecht to

testify. See, e.g., Grant v. Commissioner of Correction,

supra, 354 Conn. 50. In making that predictive assessment, the habeas court was required to assess Wecht’s

expert opinion based on his methodology and its firsthand

observation of the persuasiveness of his testimony. See,

e.g., Bowens v. Commissioner of Correction, supra, 333

Conn. 523; Taylor v. Commissioner of Correction, supra,

324 Conn. 643–44. The habeas court properly applied this

legal standard as it quoted the apt legal principles and

expressly concluded that the outcome of the petitioner’s

criminal trial would not have been different if Wecht had

testified for two principal reasons. First, the court found that Wecht’s testimony would not have persuaded the

jury because he failed to account for the shape and stellate tear around the wound, as well as the time that had

elapsed between the shooting and autopsy. Second, the

habeas court determined that Wecht’s testimony would

not have overcome the state’s overwhelming eyewitness

and forensic testimony, as well as evidence of the petitioner’s motive, that bolstered its case.

The petitioner further asks this court to apply Lapointe

on appeal to reverse the habeas court’s determination

that Wecht was not credible. This argument is outside

the question on which the petitioner requested and we

granted certification, and would necessitate our application of Lapointe instead of the habeas court’s standard.

See State v. Armadore, 338 Conn. 407, 438 n.15, 258

A.3d 601 (2021). We will not undertake the task at this

point. Doing so would not benefit the petitioner in any

event, because it is evident from the foregoing analysis

that the petitioner in the present case, unlike in Lapointe, cannot demonstrate that the reasons the habeas court

Hilton v. Commissioner of Correction

discredited Wecht were factually unsupported. The

record supports each of the habeas court’s reasons for

declining to credit Wecht’s opinion, so this case does not present the same type of “limited” circumstance this

court encountered in Lapointe that led us to reverse the

habeas court’s credibility finding in that case. Lapointe

v. Commissioner of Correction, supra, 316 Conn. 306.

Under these circumstances, we must defer to the habeas

court’s credibility determination.

We also agree with the Appellate Court that, unlike

in Lapointe, the state’s evidence of guilt in the present

case was not weak. The habeas court aptly found that the

state’s case against the petitioner was “overwhelming”

because “[t]here were multiple witnesses to the argument and ongoing feud between him and the victim.

Identification was not an issue as all parties knew each

other. There were two eyewitnesses who remained on

the scene and gave statements to [the] police identifying

[the petitioner] as the shooter and placing him standing

right next to the victim when he was shot. There were no

witnesses to [the petitioner’s claimed] third and fourth

individuals. . . . [T]he sole witness who testified in support of [the petitioner’s] claim that someone else shot

the victim was wrong about the time and location of

the shooting and did not observe a fourth witness.” The

Appellate Court has twice taken note of the strong and

overwhelming nature of the state’s case against the petitioner, once in his direct appeal and second in his appeal following his first habeas trial, and we have no reason

to disagree with those assessments of the evidence. See

Hilton v. Commissioner of Correction, supra, 161 Conn.

App. 76; State v. Hilton, supra, 79 Conn. App. 168.4

Although Lapointe did not alter a habeas court’s function as the arbiter of credibility, it provides an important

4

Although we reach the same result as the Appellate Court, our analysis differs in one important respect. We do not agree with the Appellate Court’s holding that Lapointe is legally inapposite because it involved a claimed violation of Brady v. Maryland, 373 U.S. 83, 87, 83 S. Ct. 1194, 10 L. Ed. 2d 215 (1963), whereas the petitioner in the present case asserted a Strickland claim. See Hilton v. Commissioner of

Hilton v. Commissioner of Correction

lesson to habeas courts, namely, that a habeas court must

carefully scrutinize expert opinions and forensic science

and ensure that the factual record supports its ultimate

credibility determination. We encourage habeas courts

to articulate in detail, as the habeas court did in the

present case, the way it assesses and finds an expert to

be credible or not credible so that a reviewing court, if

asked to apply Lapointe, can decide whether the record

factually supports that credibility determination. The

habeas court’s assessment as to which expert, neither,

or both, to credit often is determinative of a petitioner’s claims. See, e.g., Barlow v. Commissioner of Correction,

supra, 343 Conn. 367–68; Skakel v. Commissioner of Correction, 329 Conn. 1, 62, 188 A.3d 1 (2018), cert. denied, 586 U.S. 1068, 139 S. Ct. 788, 202 L. Ed. 2d 569 (2019).

It is therefore important that habeas courts thoughtfully

consider and deliberate on this type of evidence, as the

habeas court did in the present case.

The judgment of the Appellate Court is affirmed.

In this opinion the other justices concurred.

Correction, supra, 225 Conn. App. 331, 337–40. The habeas claim at issue in Lapointe implicated both Strickland and Brady because the petitioner there asserted that habeas counsel had rendered ineffective assistance in violation of Strickland by failing to demonstrate that the state had improperly withheld exculpatory evidence in violation of Brady. See Lapointe v. Commissioner of Correction, supra, 316 Conn. 251. Moreover, a habeas court’s predictive assessment is the same under both Strickland and Brady because “it is undisputed that the test for prejudice under Strickland is identical to the test for materiality under Brady.” Skakel v. Commissioner of Correction, 329 Conn. 1, 40 n.16, 188 A.3d 1 (2018), cert. denied, 586 U.S. 1068, 139 S. Ct. 788, 202 L. Ed. 2d 569 (2019); see also Jones v. State, 328 Conn. 84, 102, 177 A.3d 534 (2018) (noting that appellate review of Brady claims and Strickland claims is same). Thus, although we agree that Lapointe does not impact the outcome of this case, it is not because of a distinction between Strickland and Brady in this context.