Justia Connecticut Supreme Court Opinion Summaries

Michael Aronow, an orthopedic surgeon at the University of Connecticut Health Center, filed a grievance with the Health Center Appeals Committee against Jay Lieberman, the chairman of the orthopedic surgery department at the Center, accusing Lieberman of attempted intimidation and harassment. Aronow requested copies of the Committee’s report of its findings regarding Aronow’s grievance as well as the report written by the president emeritus of the University, but the Center denied Aronow’s request, concluding that the reports were exempt from disclosure pursuant to Conn. Gen. Stat. 10a-154a. The Freedom of Information Commission, however, concluded that the reports were not exempt from disclosure under the statute and ordered the center to provide Aronow with a copy of the reports free of charge. The trial court dismissed Lieberman’s appeal, concluding that the Commission properly determined that the reports did not constitute a “record of the performance and evaluation” of a faculty member under section 10a-154a and were therefore not exempt from disclosure. The Supreme Court affirmed, holding that the reports in this case did not constitute a “record of the performance and evaluation” of a state university faculty or professional staff member within the exemption created by section 10a-154a. View "Lieberman v. Aronow" on Justia Law

Defendant was convicted of possession of narcotics with intent to sell and conspiracy to possess narcotics with intent to sell. The Appellate Court reversed and ordered a new trial, concluding that the prosecutor violated a court order concerning the permissible boundaries of argument and referred to facts outside the record, thus rendering the trial fundamentally unfair. The State appealed, claiming that the prosecutor’s remarks were not improper. The Supreme Court reversed, holding that one of the prosecutor’s arguments was improper, but this improper argument did not deprive Defendant of his due process right to a fair trial because there was no reasonable likelihood that the prosecutor’s comments affected the jury’s verdict. View "State v. Martinez" on Justia Law

After a jury trial, Defendant was convicted of two counts of aggravated sexual assault of a minor, in violation of Conn. Gen. Stat. 53a-70c(a)(1) and (6), and other offenses. Defendant sought review pursuant to State v. Golding, claiming that his convictions and sentences for two counts of aggravated sexual assault of a minor violate his right to be free of double jeopardy because they constitute multiple punishments for the same offense. The Supreme Court affirmed, holding that because subdivisions (1) and (6) of section 53a-70c(a) each require proof of a fact that the other does not, and because nothing in either the statutory text or legislative history of the statute reveals a contrary legislative intent, multiple convictions under section 53a-70c for the same transaction do not run afoul of the double jeopardy clause. View "State v. Wright" on Justia Law

Petitioner was convicted of sexual assault in the first degree and risk of injury to a child for sexually abusing a four-year-old girl. Petitioner subsequently filed a petition for a writ of habeas corpus, alleging that his counsel provided ineffective assistance by failing to present expert testimony regarding the suggestibility of young children and the reliability of a child’s recollection of sexual abuse. The habeas court reversed, concluding that Petitioner established that his trial counsel had rendered ineffective assistance. The Appellate Court affirmed. The Supreme Court reversed, holding that the failure of Petitioner’s trial counsel to present the expert testimony was objectively reasonable because there was a legitimate, strategic reason for not presenting such testimony. View "Michael T. v. Comm’r of Corr." on Justia Law

Pursuant to a plea agreement, Petitioner pleaded guilty to manslaughter in the first degree with a firearm. The plea agreement stated that Petitioner would receive a total sentence of between twenty and twenty-five years’ imprisonment and that defense counsel had a right to argue for a sentence beneath the twenty-five year cap. At sentencing, defense counsel agreed with the prosecutor’s recommendation that the trial court should impose the maximum sentence under the agreement. The trial court sentenced Petitioner to twenty-five years imprisonment. Petitioner subsequently filed a petition for a writ of habeas corpus, claiming ineffective assistance of counsel. The habeas court denied relief, determining that Petitioner failed to prove ineffective assistance of counsel under Strickland v. Washington. The Appellate Court affirmed, concluding that the habeas court properly determined that Petitioner failed to prove actual prejudice under Strickland. The Supreme Court reversed in part, holding that the habeas court improperly applied Strickland to Petitioner’s ineffective assistance claim because a complete breakdown in the adversarial process occurred, and therefore, Petitioner’s claim was instead controlled by United States v. Cronic, under which prejudice should be presumed. View "Davis v. Comm’r of Corr." on Justia Law

Defendant was found not guilty of certain offenses by reason of mental disease or defect and transferred to a maximum security psychiatric facility. Defendant was charged with new, violent crimes while housed at the facility. The trial court set a monetary bond as a condition of release. Because Defendant was unable to post that bond, he was transferred to the custody of the Commissioner of Correction at a prison while awaiting trial on the new charges. Defendant appealed. The Supreme Court affirmed, holding that the trial court’s imposition of a monetary bond and, after Defendant was unable to post that bond, Defendant’s transfer to the custody of the Commissioner, did not violate Defendant’s constitutional rights to (1) bail, pursuant to the Connecticut Constitution; and (2) procedural due process, pursuant to the Fourteenth Amendment to the United States Constitution. View "State v. Anderson" on Justia Law

Defendant entered conditional pleas of nolo contendere to possession of a controlled substance with intent to sell, home invasion, robbery in the second degree, burglary in the third degree, a stealing a firearm. Defendant appealed the trial court’s denial of his motion to suppress evidence of statements he made to the police following his arrest, in which he confessed to the charged crimes. Specifically, Defendant argued that his statements should have been suppressed as the product of an illegal search because the warrant authorizing the search of his apartment was unsupported by probable cause. The Appellate Court affirmed. The Supreme Court affirmed, holding that the affidavit in support of the search warrant application established probable cause, and accordingly, the Appellate Court properly affirmed the trial court’s denial of Defendant’s motion to suppress. View "State v. Flores" on Justia Law

This case came to the Supreme Court on certification from the United States District Court for the District of Connecticut. Plaintiff sued his former employer in federal court, alleging, inter alia, that Defendants had violated Conn. Gen. Stat. 31-51q by subjecting him to discipline on account of Plaintiff’s exercise of his rights guaranteed by Conn. Const. art. I, sections 3, 4 or 14. The Supreme Court answered (1) the rule announced by the United States Supreme Court in Garcetti v. Ceballos that when employees make statements pursuant to their official duties the employees are not speaking as citizens for First Amendment purposes and the Constitution does not insulate their communications from employer discipline does not apply to a claim that an employer violated section 31-51q by subjecting an employee to discipline or discharge on account of the exercise by such an employee of rights guaranteed by Conn. Const. art. I, sections 3, 4, or 14; and (2) under the state Constitution, employee speech pursuant to official job duties on certain matters of significant public interest is protected from employer discipline in a public workplace, and section 31-51q extends the same protection to employee speech pursuant to official job duties in the private workplace. View "Trusz v. UBS Realty Investors, LLC" on Justia Law

Petitioner was convicted of reckless endangerment in the second degree and related offenses. Petitioner filed a petition for writ of habeas corpus, claiming that his trial counsel rendered ineffective assistance at his criminal trial because she chose not to pursue questioning of a potential exculpatory witness. The habeas court denied the petition. The Appellate Court dismissed Petitioner’s appeal, concluding that substantial evidence supported the habeas court’s conclusion that Petitioner had failed to establish the prejudice prong for ineffective assistance of counsel under Strickland v. Washington. The Supreme Court affirmed, holding that the Appellate Court properly dismissed Petitioner’s appeal on the ground that he had failed to satisfy the prejudice prong of Strickland. View "Staton v. Comm’r of Corr." on Justia Law

Plaintiffs, the Department of Mental Health and Addiction Services and its Freedom of Information Officer, received a request under the Freedom of Information Act from Ron Robillard for records concerning Amy Archer Gillian, who was convicted of second degree murder for the arsenic poisoning of a resident of her nursing home. Plaintiffs disclosed some, but not all, of the requested records. The Freedom of Information Commission determined that Gilligan’s medical and dental records were not exempt from disclosure. The trial court sustained Plaintiffs’ appeal as to those records. The Supreme Court reversed, holding (1) Plaintiffs had standing to appeal the decision of the Commission; and (2) the documents at issue were medical records related to the diagnosis and treatment of a patient and were, therefore, psychiatric records exempt from disclosure pursuant to Conn. Gen. Stat. 52-146e. View "Freedom of Info. Officer, Dep’t of Mental Health & Addiction Servs. v. Freedom of Info. Comm’n" on Justia Law