Justia Connecticut Supreme Court Opinion Summaries

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The Supreme Court affirmed in part and reversed in part Defendant's convictions on charges arising from two separate incidents between him and officers of the Clinton Police Department in July 2015, holding that Defendant's conviction in the case relating to events of July 19, 2015 must be reversed and the conviction in the case relating to the events of July 22, 2015 is reversed with respect to one assault count.On appeal, Defendant argued (1) evidence of certain events during the first incident should have been suppressed because those events were the result of an unconstitutional investigatory detention, and (2) his convictions of two counts of assault of public safety personnel related to the second incident was infirm because the evidence was insufficient and the trial court erred in instructing the jury. The Supreme Court reversed in part, holding (1) the trial court erred in denying Defendant's motion to suppress; and (2) a new trial was required with respect to one of the assault charges due to instructional error. View "State v. Haughwout" on Justia Law

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The Supreme Court affirmed the judgment of the trial court convicting Defendant of murder, criminal attempt to commit robbery in the first degree, conspiracy to commit robbery in the first degree, and criminal possession of a firearm, holding that the trial court did not err in denying Defendant's motions to suppress.In his suppression motions, Defendant sought to suppress (1) the firearm and related evidence seized from his residence, which evidence he argued was discovered as a result of an unlawful search, and (2) the incriminating statements he made during an interrogation at the police station, claiming the statements were made involuntarily. The Supreme Court affirmed the denial of Defendant's motions to suppress, holding (1) the trial court properly Defendant's motion to suppress the evidence obtained during the search of his residence; and (2) Defendant's statements were voluntary, and the trial court properly admitted them into evidence at trial. View "State v. Griffin" on Justia Law

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The Supreme Court affirmed the decision of the appellate court upholding the trial court's judgment of conviction in this case, holding that there was sufficient evidence for the jury to find Defendant guilty of murder.After his first two trials ended in mistrials after hung juries Defendant was convicted of murder. On appeal, Defendant argued that the jury lacked sufficient evidence to find him guilty of murder because the State failed to prove the manner, means, place, cause, and time of death. The appellate court affirmed. The Supreme Court affirmed, holding that the evidence supported Defendant's conviction of murder. View "State v. Richards" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the judgment of the trial court convicting Defendant of one count of murder with special circumstances and imposing a mandatory sentence under Conn. Gen. Stat. 53a-35a(1)(B) of life imprisonment without the possibility of release, holding that there was no error in the proceedings below.Specifically, the Supreme Court held that the trial court (1) correctly instructed the jury on the "in the course of a single transaction" element of murder with special circumstances; (2) did not commit plain error by failing to provide the jury, sua sponte, with a special credibility instruction with respect to one of the State’s witnesses, who Defendant claimed was the actual perpetrator of the murders; and (3) did not violate Defendant's state and federal constitutional rights to counsel and to present a defense by precluding defense counsel from making a certain argument in closing argument. View "State v. Silva" on Justia Law

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The Supreme Court reversed the order of the trial court requiring Defendant to submit both to an examination for sexually transmitted diseases pursuant to Conn. Gen. Stat. 54-102a(a) and to testing for human immunodeficiency virus (HIV) pursuant to section 54-102a(b), holding that the trial court erred.Defendant was charged with patronizing a prostitute who was the victim of human trafficking and conspiracy to commit trafficking in persons. The State subsequently filed a motion seeking a court order requiring Defendant to submit to the examination and testing at issue. Thereafter, several victims of Defendant's alleged misconduct filed similar motions. The trial court ordered Defendant to submit to the examination and testing. Defendant appealed. The Supreme Court reversed, holding (1) under Conn. Const. art. I, 7, the trial court must make a finding that either an examination pursuant to section 54-102a(a) or testing pursuant to section 54-102a(b), or both, would provide would provide useful, practical information; and (2) because the trial court did not apply this standard, the case must be remanded for a new hearing. View "State v. Bemer" on Justia Law

Posted in: Criminal Law
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The Supreme Court dismissed this certified appeal as moot and vacated the judgment of the appellate court dismissing Defendant's appeal, holding that the appeal was moot and that vacatur was appropriate.This appeal concerned a subpoena that Plaintiffs served on Defendant seeking to depose her. Defendant filed a motion to quash, which the trial court denied. After Defendant appealed, Plaintiffs moved for permission to file an untimely motion to dismiss, arguing that the appeal was frivolous. The appellate court granted Plaintiffs' motion and dismissed the appeal. After the Supreme Court granted certification, Plaintiffs withdrew the subpoena. The Supreme Court held (1) Plaintiffs' withdrawal of the subpoena rendered his appeal moot; and (2) under the circumstances, vacatur of the appellate court's judgment, which was adverse to Defendant, was appropriate. View "Thornton v. Jacobs" on Justia Law

Posted in: Civil Procedure
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The Supreme Court affirmed the judgment of the appellate court affirming Defendant's convictions of three distinct crimes in connection with his attack on a single victim over the course of an eight-hour period on a single day, holding that there was no error.Defendant was convicted of assault in the third degree, unlawful restraint in the first degree, and strangulation in the second degree. On appeal, Defendant argued that his constitutional right to a jury trial was violated when the trial court, rather than the jury, determined that the charges of assault and unlawful restraint were not "upon the same incident" as that giving rise to the charge of strangulation. The appellate court affirmed. The Supreme Court affirmed, holding that the trial court's determination at sentencing that the offenses of strangulation, assault, and unlawful restraint were not "upon the same incident" did not implicate the constitutional principles underlying Apprendi v. New Jersey, 530 U.S. 490 (2000), or double jeopardy concerns. View "State v. Watson" on Justia Law

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The Supreme Court reversed the judgment of the appellate court reversing the judgment of the trial court rendered in accordance with a jury verdict awarding Plaintiff damages for injuries he received from a fall on the City of Bridgeport's sidewalk, holding that the appellate court erred.On appeal, Plaintiff argued that the appellate court erred in determining, pursuant to Conn. Gen. Stat. 52-174(b), that the trial court should not have admitted into evidence a medical record containing the opinion of Plaintiff's treating physician assistant when Defendant was unable to cross-examine the physician assistant. The Supreme Court agreed and reversed, holding that the appellate court incorrectly determined that Plaintiff's medical records were inadmissible under section 52-174(b). View "DeMaria v. Bridgeport" on Justia Law

Posted in: Personal Injury
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The Supreme Court overruled Savage v. St. Aeden’s Church, 189 A. 599 (Conn. 1937), insofar as it concluded that an employee is entitled to compensation as a matter of law when, during the course of the employee's employment, he or she is injured due to an idiopathic fall onto a level floor.The Appellate Court reversed the decision of the Compensation Review Board (Board) affirming the decision of the Workers' Compensation Commissioner for the Second District (Commissioner) denying Plaintiff's application for benefits filed after she suffered a syncopal episode at her workplace, which caused her to fall backward and strike her head on the ground, concluding that, under Savage, Plaintiff's injury was compensable as a matter of law. The Supreme Court reversed after overruling the portion of Savage at issue, holding that the risk or condition must be "peculiar to the employment" for the injury to be compensable. View "Clements v. Aramark Corp." on Justia Law

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The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the trial court convicting Defendant of one count of intentional assault and one count of reckless assault, holding that the appellate court correctly concluded that the jury's verdicts of guilty of intentional assault and reckless assault were not legally erroneous.On appeal, Defendant argued that the verdicts finding him guilty of intentional assault and reckless assault were legally inconsistent because their requisite mental states of intentional and reckless were mutually exclusive. The appellate court concluded that the convictions were consistent because each mental state pertains to a different result. The Supreme Court affirmed, holding that the jury reasonably could have found that Defendant intended to cause the victim serious physical injury and simultaneously disregarded the risk that his conduct would cause the victim's death. View "State v. Alicea" on Justia Law

Posted in: Criminal Law