Justia Connecticut Supreme Court Opinion Summaries

The defendant was convicted of murder, carrying a pistol without a permit, and criminal possession of a firearm in connection with the shooting death of the victim. The defendant appealed, claiming that the trial court deprived him of his constitutional right to present a defense by not instructing the jury on the adequacy of the police investigation. He also claimed that his due process rights were violated by admitting an out-of-court identification by an eyewitness and that his confrontation rights were violated by admitting testimony from a medical examiner who did not perform the autopsy.The trial court denied the defendant's request for an investigative inadequacy instruction, finding no evidence to support the claim that the police failed to investigate other suspects or perform a victimology. The court also denied the motion to preclude the eyewitness identification, concluding that the identification procedure was not suggestive despite the omission of one statutory instruction. The court found that the eyewitness was not pressured to make an identification and that the procedure adhered to best practices.The Connecticut Supreme Court reviewed the case and affirmed the trial court's decisions. The court held that the trial court correctly declined to instruct the jury on investigative inadequacy due to a lack of supporting evidence. The court also found that the identification procedure was not suggestive and that the eyewitness's identification was reliable. Additionally, the court concluded that the medical examiner's testimony did not violate the defendant's confrontation rights, as it was based on autopsy photographs rather than the autopsy report.The court affirmed the judgment of the trial court, finding no merit in the defendant's claims and determining that any potential errors were harmless beyond a reasonable doubt. View "State v. Villanueva" on Justia Law

The case involved a defendant who was convicted of murder, attempted murder, first-degree burglary, and first-degree arson after a violent incident in which he fatally stabbed the victim, assaulted her son, and set multiple fires in the victim’s home. The events occurred in the early morning hours, with the victim’s son witnessing the attack and later identifying the defendant, a longtime family friend, as the perpetrator. The defendant initially denied involvement but later admitted to being present and described a struggle with the victim, claiming to have blacked out during the incident. The autopsy revealed the victim suffered twenty-six sharp force injuries, including multiple stab wounds, and died from blood loss.The Superior Court in the judicial district of Waterbury conducted the trial, where the jury found the defendant guilty on all counts. The defendant requested a jury instruction on manslaughter in the first degree as a lesser included offense of murder, which the trial court denied. The defendant also did not object at trial to the admission of an autopsy report prepared by a medical examiner who did not testify, nor to the testimony of another medical examiner who observed the autopsy.On direct appeal, the Connecticut Supreme Court reviewed the case. The court held that the trial court correctly denied the request for a manslaughter instruction because the evidence did not justify a conviction for manslaughter, and the distinction between reckless and intentional conduct was not sufficiently in dispute. The court also held that the defendant’s confrontation clause claim regarding the autopsy report was waived due to a strategic decision by defense counsel not to object at trial. As a result, the Supreme Court affirmed the judgment of the trial court. View "State v. Iverson" on Justia Law

Aquarion Water Company of Connecticut (Aquarion) filed a rate application with the Public Utilities Regulatory Authority (PURA) in August 2022, seeking to increase its rates to cover approximately $700 million in capital improvements made since 2013. Aquarion also sought to recover $3 million in deferred water conservation expenses and $2.2 million for its employee incentive compensation program. PURA reviewed the application and allowed Aquarion to include $650 million in plant additions completed before August 31, 2022, in its rate base but excluded $48 million in post-application plant additions. PURA also denied Aquarion’s request for the full amount of deferred conservation expenses and employee incentive compensation, reducing the approved revenue requirement to $195 million and the return on equity (ROE) to 8.7%.The trial court dismissed Aquarion’s appeal, finding substantial evidence supporting PURA’s decisions. Aquarion then appealed to the Connecticut Supreme Court, arguing that PURA acted arbitrarily and capriciously in its prudence determinations and that the rate order was confiscatory.The Connecticut Supreme Court upheld PURA’s exclusion of the $42 million in post-application plant additions, finding a discernible difference in the quality of evidence submitted for pre- and post-application additions. The court also upheld the denial of $2.2 million for the employee incentive compensation program, agreeing that PURA did not use hindsight but rather assessed the program’s future efficacy based on historical data.However, the court found that PURA improperly used hindsight to evaluate the prudence of $1.5 million in deferred conservation expenses, focusing on after-the-fact economic savings rather than the prudence of the decision at the time the expenses were incurred. The court reversed this part of the trial court’s judgment and remanded the case for further proceedings.The court also rejected Aquarion’s claim that the rate order was confiscatory, affirming that the approved ROE of 8.7% was not effectively reduced by the disallowance of certain costs and was sufficient to maintain Aquarion’s financial integrity and ability to attract capital. View "Aquarion Water Co. of Connecticut v. Public Utilities Regulatory Authority" on Justia Law

The defendant was convicted of murder and tampering with or fabricating physical evidence after a trial before a three-judge panel. The trial court suppressed the defendant's station house confession, finding it was not voluntarily made due to the defendant's physical distress and repeated requests to end the interrogation. However, the court admitted the defendant's subsequent hospital confession, deeming it spontaneous and freely made.The defendant appealed, arguing that the prosecutor improperly relied on the suppressed station house confession to secure his murder conviction, and that the admission of the hospital confession violated his due process rights as it was a product of the earlier, involuntary confession.The Connecticut Supreme Court reviewed the case. The court found the record inadequate to review the defendant's claim that the prosecutor and trial court improperly relied on the suppressed confession. The defendant failed to demonstrate that the experts who testified at trial relied on the suppressed confession in forming their opinions. The court also found that the trial court did not rely on the hospital confession in reaching its verdict, and any error in admitting the hospital confession was harmless beyond a reasonable doubt.The Connecticut Supreme Court affirmed the trial court's judgment, upholding the defendant's convictions. View "State v. Maharg" on Justia Law

The defendant, Aaron Moore, was arrested in January 2025 for his involvement in the death of John Williams. He was charged with conspiracy to commit murder, criminal possession of a pistol or revolver, criminal possession of a firearm, and carrying a pistol without a permit. The arrest warrant affidavit alleged that Moore and his friend, Eric Diaz, were in a feud with Williams, leading to a car chase and subsequent shooting where Moore and Diaz fired multiple shots at Williams, resulting in his death.The trial court set Moore's bond at $1 million and required that 30 percent of it be posted in cash, based on the state's petition. Moore moved to vacate this decision, arguing that none of the charges against him constituted a "serious firearm offense" as defined by the relevant statutes, which require that an essential element of the crime involves the use or threat of a firearm. The trial court denied Moore's motion, focusing on the serious safety risk he posed rather than whether the charges met the statutory definition of a serious firearm offense.The Connecticut Supreme Court reviewed the case and concluded that the phrase "essential element" refers to the basic legal requirements of an offense, not the factual allegations in the arrest warrant. The court found that none of the charges against Moore required proof that he used or threatened the use of a firearm as an essential element. Therefore, the trial court's imposition of the 30 percent cash bond requirement was incorrect. The Connecticut Supreme Court vacated the trial court's order. View "State v. Moore" on Justia Law

The defendant was convicted of murder and carrying a pistol or revolver without a permit. The key evidence against him included two recorded police interviews with Daequan Carr, the state's primary witness, who identified the defendant as the shooter. Carr was uncooperative at trial, leading the prosecution to introduce his prior statements under the Whelan rule, which allows prior inconsistent statements to be used substantively if certain conditions are met.The trial court admitted Carr's interviews, finding his trial testimony inconsistent with his prior statements. Carr's father, Dennis Cobia, also made statements during one interview, which the court allowed to the extent Carr adopted them. The jury found the defendant guilty, and he was sentenced to fifty-five years in prison.The defendant appealed, arguing that Carr's trial testimony was not inconsistent with his prior statements and that the trial court erred in admitting Cobia's statements. He also contended that the court improperly admitted a Facebook photo and Snapchat video showing him with items similar to those used in the crime.The Connecticut Supreme Court found that the trial court abused its discretion in admitting Carr's interviews. Carr's ambiguous statements about his recollection did not clearly establish inconsistency, and the prosecution did not sufficiently probe his memory or attempt to refresh it. The court also failed to adequately determine whether Carr refused to testify. The error was not harmless, as Carr's identification of the defendant was crucial, and no other evidence directly linked the defendant to the crime.The court clarified that adopted statements could be admitted under Whelan if unequivocally adopted by the witness. However, the trial court improperly delegated to the jury the task of determining which of Cobia's statements were adopted by Carr. The court upheld the admission of the Facebook photo and Snapchat video, finding their probative value outweighed any prejudicial effect.The judgment was reversed, and the case was remanded for a new trial. View "State v. Hamilton" on Justia Law

The defendant was convicted of murder after fatally stabbing his girlfriend in their shared apartment. The incident occurred while the victim’s son was home, though he did not witness the attack. After the killing, the defendant fled in the victim’s car and communicated with family members via Facebook, making statements about the altercation and his intent to leave the country. He was later apprehended in New York, where he made statements to police both spontaneously and during a subsequent interview, in which he confessed to the killing. During the police interview, photographs were taken of the defendant to document any injuries.In the Superior Court for the judicial district of Waterbury, the defendant moved to suppress his statement to the Waterbury police, arguing it was obtained in violation of his right to counsel under Miranda and Edwards. The trial court agreed in part, suppressing the statement from the prosecution’s case-in-chief but allowing its use for impeachment if the defendant testified, relying on State v. Reid. The court also admitted photographs taken of the defendant, finding they were obtained through standard police procedure and not as a result of the Miranda violation. Additionally, the court permitted the late disclosure of a witness, the victim’s sister-in-law, after finding no prejudice to the defense.The Connecticut Supreme Court affirmed the conviction. It held that the state constitution does not prohibit the use of a voluntary statement obtained in violation of Miranda for impeachment purposes, declining to overrule State v. Reid. The court also held that the photographs were admissible because they had an independent source in routine police procedure. Finally, the court found no abuse of discretion or violation of the defendant’s right to a fair trial in allowing the late-disclosed witness to testify, as the defendant suffered no demonstrable prejudice. View "State v. Haynes" on Justia Law

The case involved a fatal stabbing that occurred during a confrontation inside the victim’s apartment. The defendant and the victim were both acquainted with a woman named Menendez, who had relationships with both men. In the period leading up to the incident, the defendant became increasingly controlling and jealous regarding Menendez’s interactions with the victim. On the day of the stabbing, Menendez was staying with the victim, and after a series of tense interactions and text messages, the defendant arrived at the victim’s apartment. Shortly after the defendant’s arrival, a violent altercation ensued, resulting in the victim being stabbed in the chest and later dying from his injuries. The defendant admitted to stabbing the victim but claimed he acted in self-defense, asserting that the victim attacked him with a knife first.The case was tried before the Superior Court in the judicial district of Hartford. At trial, the state presented testimony from Menendez, a medical examiner, a detective, and an inmate who had shared a cell with the defendant. The state’s evidence included testimony that contradicted the defendant’s account, suggesting that the defendant brought the knife to the apartment and was the only person armed during the struggle. The jury found the defendant guilty of murder, rejecting his self-defense claim. The defendant was sentenced to thirty-five years of incarceration and appealed his conviction, arguing that the evidence was insufficient to disprove his claim of self-defense beyond a reasonable doubt.The Connecticut Supreme Court reviewed the case. The court held that the state presented sufficient evidence for the jury to find, beyond a reasonable doubt, that the defendant either did not actually believe he was in imminent danger of deadly physical force or, if he did, that such a belief was not objectively reasonable. The court affirmed the conviction, concluding that the state met its burden of disproving the defendant’s justification defense. View "State v. Ramsey" on Justia Law

The defendant was convicted of felony murder and attempted robbery in the first degree, among other charges, following an incident where another individual, Christian, shot and killed the victim, Rodney, during a scuffle that ensued after the defendant attempted to rob Rivera. The defendant appealed, arguing that the state needed to prove that Christian was an accessory to the attempted robbery to secure a felony murder conviction.The trial court had instructed the jury on the felony murder statute, which does not require the state to prove that a participant in the crime was an accessory. The defendant was found guilty of felony murder, attempted robbery, and firearm offenses, but not guilty of murder as an accessory. The trial court vacated the manslaughter conviction on double jeopardy grounds and sentenced the defendant to forty years in prison.The Connecticut Supreme Court reviewed the case and held that the felony murder statute does not require the state to establish that a participant who caused the death was an accessory to the predicate felony. The court found sufficient evidence to support the conviction, noting that Christian's actions were in furtherance of the attempted robbery and that the killing occurred during the continuous sequence of events surrounding the attempted robbery.The court also rejected the defendant's claim of instructional error, as the trial court's instructions were legally proper and did not need to include a requirement for proving accessorial liability. Additionally, the court found that the defendant had waived his confrontation clause claim by not objecting to the admission of Rivera's video-recorded interviews at trial.Finally, the court declined to overrule its precedent in State v. Newsome, which allows a reliable out-of-court statement to serve as the sole evidentiary basis for a conviction. The court concluded that Rivera's statements were reliable and corroborated by other evidence, thus sufficient to establish the defendant's intent to commit attempted robbery.The judgment of the trial court was affirmed. View "State v. Hinton" on Justia Law

The plaintiff in error, Gregory Johnson, challenged his summary conviction of three counts of criminal contempt for repeatedly interrupting and directing racial slurs and other profanities at the court during his habeas corpus trial. He claimed that the trial court deprived him of his right to due process by not postponing the contempt proceeding and by not ordering it to be held before a different judge.The trial court, acting in the capacity of a trial court for the habeas proceeding, conducted the first day of the trial on April 4, 2023, and resumed on May 4, 2023. The plaintiff, appearing virtually, refused to comply with the court's instructions, used racial slurs, and swore at the court. The court warned the plaintiff multiple times before finding him in contempt. The court then appointed counsel for the plaintiff, allowed a private consultation, and provided an opportunity for both the plaintiff and his counsel to speak before sentencing.The Connecticut Supreme Court reviewed the case and found that the trial court's summary contempt proceeding substantially complied with the requirements of Practice Book § 1-16, which ensures fairness in the adjudication of summary criminal contempt. The court concluded that the plaintiff's behavior obstructed the orderly administration of justice, justifying the trial court's decision not to defer the proceeding under Practice Book § 1-17. The court also determined that the trial judge did not become personally embroiled in the controversy, as the judge maintained a calm demeanor and provided the plaintiff with multiple warnings and opportunities to explain his behavior.The court rejected the plaintiff's claim that his medical issues and alleged incompetency warranted deferral of the contempt proceeding. The trial court had observed the plaintiff's behavior and found him competent, and his counsel did not request a competency evaluation. The Connecticut Supreme Court dismissed the writ of error, upholding the trial court's findings and sentencing. View "Johnson v. Superior Court" on Justia Law