Justia Connecticut Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of larceny in the first degree and conspiracy to commit larceny in the first degree. The convictions were based in part on evidence that included warrantless recordings of telephone conversations between Defendant and Jacqueline Becker, which were recorded without Defendant’s consent but with the consent of Becker. The Supreme Court affirmed the convictions, holding (1) recording a telephone conversation with the consent of one party to that conversation does not violate the prohibition on unreasonable searches and seizures under the Connecticut Constitution; and (2) the trial court’s failure to conduct an independent inquiry regarding Defendant’s competence to stand trial was not improper. View "State v. Skok" on Justia Law

After a jury trial, Defendant was convicted of murder. The Supreme Court affirmed, holding (1) Defendant did not preserve his claim that the trial court had an obligation to provide, sua sponte, a jury instruction on the risk of misidentification by an eyewitness pursuant to State v. Ledbetter; (2) the trial court did not abuse its discretion in the manner in which it conducted its inquiry into the allegation of juror bias; and (3) Defendant’s exclusion from the hearing concerning possible juror bias was not a violation of his constitutional rights to be present at a critical stage of the proceedings, to counsel, and to be presumed innocent. View "State v. Dixon" on Justia Law

After a jury trial, Defendant was convicted of first degree assault, first degree unlawful restraint, and carrying a dangerous instrument. Defendant appealed, claiming that his constitutional rights to confrontation, to present a defense and to due process were violated when the trial court disclosed only four pages of the psychiatric records of E.P., a state witness, and prohibited Defendant from consulting with an expert witness as to the four disclosed pages. The Appellate Court affirmed. The Supreme Court affirmed, holding that any error in releasing only four pages of E.P.’s psychiatric records and in limiting Defendant’s ability to consult with an expert as to the disclosed pages was harmless beyond a reasonable doubt. View "State v. Santos" on Justia Law

Defendant was found guilty of capital felony and sentenced to death. While Defendant’s appeal was pending, the legislature passed Public Act 12-5, which repealed the death penalty for all crimes committed on or after April 25, 2012. On June 12, 2012, the Supreme Court affirmed Defendant’s judgment of conviction but reversed his death sentence and remanded for a new penalty phase hearing, concluding that the trial court improperly had failed to disclose to Defendant certain confidential records that were mitigating in nature. Defendant filed a motion for reconsideration, claiming that the adoption of P.A. 12-5 leads to the conclusion that capital punishment has ceased to comport with state constitutional requirements. The Supreme Court agreed and reversed Defendant’s sentence of death on the capital felony count, holding that the enactment of P.A. 12-5, when considered in light of the history of the death penalty in the state and other recent legal developments, compels the conclusion that capital punishment, as currently applied, constitutes cruel and unusual punishment in violation of the constitution of Connecticut. Remanded with direction to sentence Defendant to life imprisonment without the possibility of release. View "State v. Santiago" on Justia Law

After a hearing, the trial court terminated the parental rights of Mother as to her two minor children. Mother appealed, arguing that the trial court violated her right to due process when it failed to canvass her about her decision to waive her right to a full trial and to not contest the prosecution’s exhibits. The Appellate Court affirmed, concluding that Mother’s constitutional claim failed under the third prong of State v. Golding. Specifically, the Court concluded that, in order to prevail on an unpreserved claim under Golding, which requires that a party establish that an alleged constitutional violation “clearly exists,” a party must point to binding Connecticut precedent. The Supreme Court reversed, holding (1) the absence of existing Connecticut precedent does not preclude consideration of a claim under Golding; (2) the trial court’s failure to canvass Mother did not constitute a denial of her right to due process; but (3) the Court is warranted in using its supervisory authority over the administration of justice to impose a canvass rule requiring that a trial court canvass all parents who do not consent to the termination immediately before a parental rights termination trial, in order to ensure the overall fairness of the termination of parental rights process. View "In re Yasiel R." on Justia Law

After a jury trial, Defendant was convicted of capital felony, murder, and felony murder. The convictions arose from the killing of a single victim. The Appellate Court reversed in part and and remanded the case with direction to vacate Defendant’s convictions of murder and felony murder, concluding that those convictions violated constitutional protections against double jeopardy because they were cumulative of the controlling conviction of capital felony. The State appealed, asserting that vacatur was not the appropriate remedy for Defendant’s cumulative conviction of felony murder that violated his double jeopardy protections. The Supreme Court affirmed, holding that the vacatur remedy set forth in State v. Polanco should extend to scenarios like Defendant’s, thus making it appropriate to vacate his cumulative felony murder conviction. View "State v. Miranda" on Justia Law

Petitioner pleaded nolo contendere to a charge of assault in the first degree. Petitioner filed an amended habeas petition alleging that his trial counsel had failed to provide sufficient information to enable him to make an informed decision about whether to plead nolo contendere or to proceed to trial. The habeas court denied the petition, concluding that Petitioner was not prejudiced by his counsel’s alleged errors. The Appellate Court reversed, concluding that the prejudice standard enunciated in Copas v. Commissioner of Correction that the habeas court applied in this case was inconsistent with federal law concerning the prejudice prong. The Commissioner of Correction appealed, claiming that the Appellate Court improperly determined that the habeas court applied an incorrect legal standard. The Supreme Court dismissed the appeal for lack of subject matter jurisdiction, as the Commissioner was not aggrieved by the judgment of the Appellate Court and Copas has already been overruled sub silencio in subsequent decisions by the Court. View "Carraway v. Comm’r of Corr." on Justia Law

After a jury trial, Defendant was convicted of murder. On appeal, Defendant argued, among other things, that he was entitled to a new trial because the trial court improperly forced him to choose between his constitutional right to counsel and his constitutional right to testify on his own behalf after defense counsel stated that he would be self-represented if he testified against their advice. The Appellate Division affirmed, concluding that Defendant waived his right to counsel when he elected to testify at trial. The Supreme Court reversed, holding (1) Defendant was not represented by counsel during his testimony; and (2) Defendant was entitled to a new trial because he did not voluntarily relinquish his right to counsel. Remanded for a new trial. View "State v. Francis" on Justia Law

After a jury trial, Defendant, the Hartford Roman Catholic Diocesan Corporation, was found guilty of negligently and recklessly assigning Father Ivan Ferguson to serve as the director of Saint Marty’s Elementary School, where he sexually abused Plaintiff from 1981 through 1983. The Supreme Court affirmed, holding (1) there was sufficient evidence to support the jury’s verdict; (2) the trial court did not commit prejudicial error in its evidentiary rulings; (3) the trial court properly granted Plaintiff’s motion to strike Defendant’s laches defense; and (4) the retroactive application of certain amendments to the applicable statute of limitations to revive Plaintiff’s otherwise time barred claims did not violate Defendant’s substantive due process rights under the Connecticut Constitution. View "Doe v. Hartford Roman Catholic Diocesan Corp." on Justia Law

Petitioner entered a plea of nolo contendere to felony murder and related crimes. Petitioner was sixteen years old when he committed the crimes. The trial court sentenced Petitioner to a total effective prison term of fifty years with no possibility of parole. After Petitioner’s conviction and sentence became final, the U.S. Supreme Court decided Miller v. Alabama. Petitioner filed a petition for a writ of habeas corpus arguing that the statutory authority under which his fifty year prison term with no possibility of parole was imposed violated the Eighth Amendment as applied to him. The habeas court granted summary judgment for the State, concluding that Miller did not apply to Petitioner’s sentence. The Supreme Court reversed, holding (1) Miller applies retroactively under Connecticut law to cases arising on collateral review; and (2) Miller applies to the imposition of a fifty year sentence on a juvenile offender. Remanded. View "Casiano v. Comm’r of Corr." on Justia Law