Conn. Justices OK In-Court ID After Tainted Police Photo Array

(May 26, 2026, 8:19 PM EDT) -- The Connecticut Supreme Court on Tuesday affirmed a man's murder and firearms convictions, ruling a trial judge properly allowed an eyewitness to point to the defendant in court after suppressing the same witness's earlier out-of-court identification as the product of "unnecessarily suggestive and unreliable" police questioning during a photo array.

In a unanimous opinion authored by Justice Joan K. Alexander, the state high court ruled Yamil Rohena's state and federal due process rights were not violated when witness Shamar Coachman-Brown identified him in court during questioning about the Jan. 4, 2020, killing of Kwadir Paris. That is because Coachman-Brown had an independent basis for recognizing Rohena as the killer, the justices held.

Rohena and Coachman-Brown had known one another since 2014 and had socialized on several occasions, according to the opinion. Rohena had also dated the witness's cousin, the justices noted. Also, Coachman-Brown spoke with Rohena for three minutes in the lead-up to the shooting in the early morning hours of Jan. 4, 2020, according to the opinion.

"With respect to the day of the victim's murder, Coachman-Brown explained that he was with the defendant before and during the shooting, and he was able to recognize the defendant by his face and voice," the justices said. "Coachman-Brown also recalled some of the items of clothing the defendant was wearing at the time of the crime."

Coachman-Brown later testified with "100 percent certainty that the defendant was the person who had shot the victim," the court said.

The justices declined Rohena's request for a new rule that would protect defendants from witnesses who latch onto suspect identifications after police prodding.

Though the high court said several of its past decisions recognized "the growing body of scientific research exposing the fallibility of eyewitness identifications," this case did not provide the proper vehicle to challenge current law because of the witness's "personal familiarity" with the defendant.

"The record establishes by clear and convincing evidence that Coachman-Brown had an independent basis for identifying the defendant, which was untainted by the suggestive out-of-court identification procedure," the justices said.

The justices hinted that a stranger's identification of a defendant under similar factual circumstances might warrant a different conclusion.

Rohena argued in-court identifications should be presumed inadmissible if they followed tainted police photo lineups. If his proposed rule was adopted, "the state would then bear the burden of proving by clear and convincing evidence that the in-court identification is nevertheless reliable," according to the opinion.

The justices declined Rohena's invitation to adopt a new admissibility rule, though they acknowledged adding additional protections to federal eyewitness identification standards in other cases, including, in some instances, by requiring trial judges to pre-screen witnesses who identify defendants for the first time.

The court said it was wary of the "very substantial likelihood of irreparable misidentification," but did not see an issue in Coachman-Brown identifying Rohena in court.

According to the opinion, the police arrested Coachman-Brown in an unrelated case, but then questioned him on Jan. 9, 2020, about the Paris murder.

Coachman-Brown initially denied involvement, but a detective cautioned the witness he may go to prison if he was lying. Coachman-Brown then admitted he was present and identified the assailant as someone known as either "Moolah" or "L.A."

Another detective presented an eight-person photo array containing Rohena's photo. Coachman-Brown said he didn't recognize anyone. The police handed Coachman-Brown the photos again, and Coachman-Brown acknowledged he recognized Rohena as his cousin's ex-boyfriend.

The second detective asked Coachman-Brown if the individual he identified was really called "Moya," Rohena's known nickname. Coachman-Brown said he knew the individual as "Moolah" or "L.A." The witness then said the individual resembled the shooter, though he added the caveat that he wasn't positive.

Another detective joined the questioning session and accused Coachman-Brown of lying. Coachman-Brown eventually admitted Rohena was known as "Moya" and identified him as the shooter.

Coachman-Brown later testified he lied during early portions of the Jan. 9, 2020, interview, because he feared both retaliation and jail.

The Connecticut justices said Tuesday "the central issue at trial was the identity of the shooter." Rohena elected a jury trial on the murder charge and a bench trial on a criminal weapon possession charge. He was convicted on both and sentenced to 45 years in prison.

"I'm disappointed that the court did not find for Mr. Rohena, or adopt a state constitutional test that would match the one already used for out-of-court identifications," his attorney Lisa J. Steele told Law360 on Tuesday.

"I will be discussing with Mr. Rohena the next steps for the case," Steele added.

Connecticut's Division of Criminal Justice said the court "appropriately and carefully considered the defendant's appellate claims."

"Kwadir Paris' life was senselessly cut short, and our thoughts remain with the victim's family and loved ones," a spokesperson added.  

Connecticut is represented by Alexander A. Kambanis, Kelly E. Davis and Stacey Cox of the state's Office of the Chief State's Attorney.

Rohena is represented by Lisa J. Steele.

The case is State of Connecticut v. Yamil Rohena, case number SC 21020, in the Supreme Court of the State of Connecticut.

--Editing by Lakshna Mehta. 

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