Justia Connecticut Supreme Court Opinion Summaries

Brenda Puryear filed a complaint with the Commission on Human Rights and Opportunities on behalf of her minor daughter, Sarah, alleging that Echo Hose Ambulance and the city of Shelton had discriminated and retaliated against Sarah on the basis of her race and color in violation of the Connecticut Fair Employment Practices Act (CFEPA) and Title VII of the Civil Rights Act. The Commission’s human rights referee struck the complaint on the ground that Sarah was not an employee under the “remuneration test” used to resolve similar federal causes of action. The trial court dismissed the Commission’s appeal, concluding that the referee properly applied the remuneration test. The Appellate Court affirmed. The Commission appealed, arguing that the Appellate Court erred in applying the federal remuneration test rather than Connecticut’s common-law “right to control” test to determine whether an unpaid volunteer is an “employee” under the CFEPA. The Supreme Court affirmed, holding that the Appellate Court did not err in concluding that the remuneration test is the appropriate test for determining whether a volunteer is an employee under CFEPA. View "Commission on Human Rights & Opportunities v. Echo Hose Ambulance" on Justia Law

Defendant entered conditional pleas of nolo contendere to one count each of manufacturing a bomb and possession of child pornography in the first degree. Defendant appealed the trial court’s denial of his motion to suppress evidence discovered after the execution of an administrative search warrant at his apartment, arguing that the trial court erred in denying his motion because the administrative search warrant was invalid and improperly executed. The Supreme Court affirmed, holding that the administrative search warrant was valid because (1) the superior court judge who issued the administrative search warrant had the authority to issue the warrant; (2) the warrant was supported by the requisite probable cause; and (3) there was no error in the issuance of the warrant during an ex parte proceeding. Further, the search was lawful because excessive force was not used during its execution. View "State v. Saturno" on Justia Law

People for the Ethical Treatment of Animals, Inc. (Plaintiff) submitted a freedom of information request to the University of Connecticut Health Center (Defendant) for correspondence between Defendant and the National Institutes of Health regarding potential noncompliance with federal animal welfare guidelines. Defendant provided sixty-one pages of redacted records. The redactions were names of individuals who had violated federal protocols and federal grant identification numbers that could be used to identify those individuals. Plaintiff filed a complaint against Defendant with the Freedom of Information Commission (Commission). While the complaint was pending, the Commissioner of the Department of Administrative Services (Department) determined that there were reasonable grounds to believe that the disclosure of the redacted material could result in a safety risk. The Commission upheld the determination. The trial court sustained Plaintiff’s appeal, concluding that the Commission applied the wrong standard of review when it sustained Plaintiff’s appeal. The Supreme Court reversed, holding that the Commission applied the proper standard of review and properly upheld the Department’s determination. View "People for Ethical Treatment of Animals, Inc. v. Freedom of Info. Comm’n" on Justia Law

After a joint jury trial with his codefendant, Petitioner was convicted of ten charges arising from a murder and robbery. The Appellate Court affirmed. Petitioner thereafter filed a petition for a writ of habeas corpus, claiming that his trial counsel provided ineffective assistance by failing to conduct an adequate pretrial investigation and failing adequately to present a defense at trial. The habeas court granted the petition and ordered that Petitioner’s conviction be set aside, concluding that counsel’s failure to obtain information regarding a stolen cell phone before trial was deficient performance and that the deficient performance prejudiced Petitioner’s defense. The Supreme Court reversed, holding that counsel’s failure to investigate the issue of the stolen cell phone evidence was not prejudicial under Stickland v. Washington. View "Horn v. Comm’r of Corr." on Justia Law

The petitioner was convicted by a three-judge​ panel and sentenced to death for the murder of a police officer in December, 1992. The Connecticut Supreme Court affirmed the conviction and sentence in 2003 and the U.S. Supreme Court denied certiorari. The petitioner filed a petition for a writ of habeas corpus, claiming that trial and appellate counsel rendered constitutionally ineffective assistance by failing to raise or sufficiently present several claims. The habeas court rejected each claim. On appeal, the petitioner raised 13 separate issues, most concerning his death sentence, and a few related to his capital felony conviction. The Connecticut Supreme Court reversed his death sentence, citing its decisions in State v. Santiago (2015) and State v. Peeler (2016). The court rejected claims that the criminal trial court lacked subject matter jurisdiction because the state used a short-form information to charge him; that trial counsel rendered constitutionally ineffective assistance with respect to testimony by an individual who was with petitioner at the time of the murder and who, he alleged, was treated with leniency; and that international law precluded his conviction for a capital felony. View "Reynolds v. Comm'r of Corr." on Justia Law

After a jury trial, Defendant was convicted of two counts of assault in the second degree. Defendant appealed, arguing that the trial court’s denial of his motion to suppress his statements to the police made during his booking violated his Fifth Amendment rights and that he was subjected to custodial interrogation without Miranda warnings at the crime scene. The Appellate Court affirmed, holding that the public safety exception to Miranda, as articulated in New York v. Quarles, applied. The Supreme Court affirmed, holding that, based on the circumstances of this case, the public safety exception applied. View "State v. Smith" on Justia Law

Defendant entered a conditional plea of nolo contendere to possession of a controlled substance with intent to sell. Prior to entering the plea, Defendant moved to suppress evidence seized from his vehicle, claiming that the police did not possess a reasonable and articulable suspicion that he was engaged in or about to engage in criminal activity. On appeal, Defendant challenged the the trial court’s denial of his motion to suppress. The Appellate Court reversed, concluding that the trial court’s determination that the police possessed a reasonable and articulable suspicion that criminal activity was afoot when they detained Defendant was incorrect. The Supreme Court reversed, holding that, under the totality of the circumstances, the police possessed a reasonable and articulable suspicion to detain Defendant outside a known drug location where Defendant had previously acted in a manner consistent with drug activity. View "State v. Peterson" on Justia Law

Defendant pleaded guilty to harassment in the second degree and criminal trespass in the first degree and was sentenced to one year incarceration, execution suspended, and two years of probation. Defendant was later charged with violating the conditions of his probation. After a hearing, the trial court found that Defendant violated the conditions of his probation, continued Defendant’s probation, and added new conditions. The Supreme Court affirmed, holding (1) the trial court properly admitted evidence that Defendant argued should have been suppressed; (2) the evidence was sufficient to demonstrate that Defendant violated the terms of his probation; (3) the trial court did not err in admitting certain hearsay evidence; and (4) Defendant waived his Second Amendment right to possess firearms when he agreed to the condition of his probation barring him from possessing firearms. View "State v. Maietta" on Justia Law

After a jury trial, Defendant was convicted in two consolidated cases of attempted murder, two counts of risk of injury to a child, and murder. The Supreme Court reversed, concluding that the trial court improperly granted the State’s motion to disqualify his chosen attorney, Gary Mastronardi, and that the improper disqualification was structural error requiring a new trial. On remand, Defendant filed a motion asking the State to fund Mastronardi’s private fee or, alternatively, to dismiss the charges against him on the grounds that he was now indigent and tat Mastronardi would not represent him at the new trial at the rate paid to assigned counsel by the Division of Public Defender Services. The trial court denied Defendant’s motion, concluding that the Supreme Court’s decision Peeler I did not require it. After a second jury trial, Defendant was found guilty on all counts. The Supreme Court affirmed, holding that the trial court did not violate Defendant’s right to counsel of choice at his new trial by denying his funding motion. View "State v. Peeler" on Justia Law

After a jury trial, Defendant was convicted of crimes committing during a string of armed robberies in the cities of Stamford and Norwalk and the town of Greenwich. Defendant appealed, arguing (1) his constitutional right to counsel was violated when the trial court admitted incriminating statements he made regarding the Norwalk and Greenwich robberies while he was represented by counsel in the case involving the Stamford robbery; and (2) the trial court violated his constitutional right to confrontation by restricting defense counsel’s cross-examination of a key prosecution witness. The Supreme Court affirmed, holding that the trial court’s admission of the incriminating statements and its restrictions on counsel’s cross-examination of the witness did not violate Defendant’s Sixth Amendment rights or constitute an abuse of discretion. View "State v. Leconte" on Justia Law