Justia Connecticut Supreme Court Opinion Summaries

Articles Posted in Criminal Law

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After a jury trial, Defendant was convicted of, among other charges, carrying a pistol without a permit and unlawful possession of a weapon in a vehicle. Defendant was sentenced to a total effective term of twelve years of incarceration. The appellate court reversed in part and affirmed in part, holding that the evidence was insufficient to sustain Defendant’s conviction for carrying a pistol without a permit and unlawful possession of a weapon in a vehicle because the State failed to offer direct evidence to prove that Defendant lacked a temporary state pistol permit issued by a town in the first instance. The Supreme Court reversed in part, holding (1) the jury reasonably could have concluded that the evidence established that Defendant did not possess any pistol permit beyond a reasonable doubt; and (2) therefore, Defendant was properly found guilty of carrying a pistol without a permit and unlawful possession of a weapon in a vehicle. View "State v. Davis" on Justia Law
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After a jury trial, Defendant was convicted of murder. On appeal, Defendant’s principal claim was that the trial court violated his constitutional right to present a defense by refusing either to issue a summons to secure the attendance of a material witness in support of a theory of third-party culpability or to allow Defendant to introduce that witness’ statement to the police in lieu of her live testimony. The Supreme Court affirmed, holding (1) regarding Defendant’s argument regarding the issuance of a summons for the witness, defense counsel’s failure to locate the out-of-state witness with any reasonable degree of certainty precludes relief; and (2) none of Defendant’s remaining claims warrant reversal. View "State v. Bennett" on Justia Law

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After a jury trial in 1997, Petitioner was found guilty of murder and criminal possession of a firearm. the trial court sentenced Petitioner to an aggregate term of sixty years’ imprisonment. Petitioner later filed an amended petition for a writ of habeas corpus containing four counts. The habeas court denied the petition. The appellate court affirmed, concluding that Petitioner failed to meet his burden of demonstrating that the deficient performance of defense counsel in responding to the trial court’s treatment of a jury note had prejudiced Petitioner. The Supreme Court affirmed, holding that Petitioner received constitutionally adequate representation at trial. View "Taylor v. Commissioner of Correction" on Justia Law
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After a jury trial, Defendant was convicted of three counts of interfering with an officer. The Appellate Court reversed, concluding that the trial court abused its discretion in allowing the state to allow a midtrial amendment charging additional offenses. The Supreme Court affirmed, holding (1) the trial court abused its discretion in allowing the state to amend the information without good cause to charge additional offenses, but that impropriety does not require reversal in the absence of prejudice; and (2) the improper amendment was not harmless beyond a reasonable doubt under the circumstances of this case. View "State v. Ayala" on Justia Law
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Petitioner was convicted of murder and other crimes. Petitioner filed a petition for writ of habeas corpus alleging ineffective assistance of counsel at Petitioner’s underlying criminal trial and on direct appeal. The petition was denied. Petitioner then filed a second habeas petition alleging ineffective assistance of habeas counsel in the first habeas proceeding. The habeas court denied the petition. Petitioner later filed a third habeas petition alleging, inter alia, ineffective assistance of habeas counsel in the second habeas proceeding. The habeas court dismissed these counts, concluding that Petitioner had failed to state a cognizable claim because the statutory right of indigent habeas petitions to counsel under Conn. Gen. Stat. 51-296(a) is limited to “effective representation by…first habeas counsel.” The Supreme Court reversed, holding that common law authorizes a third habeas petition as a proper vehicle to vindicate the right to competent assigned counsel in a second habeas proceeding. Remanded. View "Kaddah v. Commissioner of Correction" on Justia Law
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After a jury trial, Defendant was found guilty of two counts of sexual assault in the first degree, three counts of sexual assault in the fourth degree and one count of risk of injury to a child. The convictions stemmed from allegations that Defendant sexually assaulted his girlfriend’s daughter. During the trial, the trial court granted the State’s motion in limine to exclude evidence of a prior allegation of sexual abuse made by the victim against her father’s then wife. Defendant appealed, arguing that the trial court erred in excluding evidence of the prior allegation and subsequent investigation. The Supreme Court dismissed the appeal as moot, as there were independent bases for the trial court’s exclusion of the evidence at issue that Defendant failed to challenge on appeal. View "State v. Lester" on Justia Law
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After a jury trial in 2002, Petitioner was found guilty of the 1975 murder of his neighbor. Nearly eight years after his conviction and after Petitioner’s prior unsuccessful challenges to his conviction, Petitioner filed this habeas petition, claiming that his trial counsel rendered constitutionally ineffective assistance in several respects. The habeas court granted the petition, concluding that counsel was ineffective on three grounds. The Commissioner of Correction appealed. The Supreme Court reversed the judgment of the habeas court and remanded with direction to render judgment denying the petition, holding (1) the habeas court erred in concluding that Petitioner’s representation was ineffective for the three reasons previously identified; and (2) none of Petitioner’s alternative grounds for relief entitled Petitioner to habeas relief. View "Skakel v. Commissioner of Correction" on Justia Law
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Defendant pleaded nolo contendere to four count of criminal possession of a firearm. Defendant appealed, arguing that the trial court erred in denying his motion to suppress certain evidence discovered following the execution of a search warrant at his house because the warrant was issued without a showing of probable cause. The Supreme Court affirmed the judgment of the trial court, holding that, on he basis of the Court’s review of the search warrant affidavit in its entirety, the trial court properly found that the facts submitted were sufficient to support a finding of probable cause. View "State v. Holley" on Justia Law

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After a jury trial, Defendant was convicted of sexual assault in the first degree and other offenses. The trial court rendered judgment in accordance with the jury’s verdict. The Appellate Court reversed the judgment and remanded the case for a new trial, holding that the State deprived Defendant of his constitutional right to remain silent when the prosecutor noted twice during closing arguments that Defendant had not testified in his own defense. The Supreme Court affirmed, holding (1) the prosecutor’s two statements clearly violated Defendant’s Fifth Amendment right to remain silent; and (2) the State failed to meet its burden of proof that the prosecutor’s comments were harmless beyond a reasonable doubt. View "State v. A. M." on Justia Law

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Petitioner was charged with several criminal offenses. Petitioner pleaded not guilty by reason of mental disease or defect. After a nonadversarial proceeding, the court rendered a judgment acquitting Petitioner of all offenses on the basis of mental disease or defect and committed Petitioner to the custody of the Commissioner of Mental Health and Addiction Services (Respondent) for a period not to exceed twenty-five years. Respondent later transferred custody of Petitioner to the jurisdiction of the Psychiatric Security Review Board. Petitioner remained committed to the custody of the Board for more than twenty-five years. Petitioner then filed a petition for habeas corpus challenging his extended confinement. The habeas court denied Petitioner’s petition. The Supreme Court affirmed, holding (1) the habeas court properly denied Petitioner relief on his claim regarding the knowing and voluntary nature of his plea; and (2) the habeas court correctly determined that Petitioner did not receive ineffective assistance of counsel. View "Dyous v. Commissioner of Mental Health & Addiction Services" on Justia Law