Justia Connecticut Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of murder and tampering with physical evidence. Defendant appealed, arguing that the trial court erred in failing to suppress (1) certain oral statements made to police officers after his apprehension on the ground that the statements were the result of a custodial interrogation without his having been read his Miranda warnings, and (2) a statement he made after being given his Miranda warnings on the ground that it was the product of coercion. The Supreme Court affirmed, holding that the trial court properly denied Defendant’s motion to suppress, as (1) Defendant was not subjected to custodial interrogation before receiving the Miranda warnings; and (2) Defendant’s confession was made voluntarily. View "State v. Ramos" on Justia Law

After a jury trial, Petitioner was found guilty of murder and carrying a pistol without a permit. The Appellate Court affirmed on direct appeal. Thereafter, Petitioner collaterally attacked his conviction by filing a petition for a writ of habeas corpus, claiming that his trial attorney had rendered ineffective assistance of counsel. The habeas court denied the habeas petition. On appeal, Petitioner raised for the first time a new theory as to why his attorney had rendered ineffective assistance. The Appellate Court declined to review Petitioner’s claim on the grounds that that review under State v. Golding is not available for unpreserved claims of error raised for the first time in a habeas appeal. The Supreme Court affirmed, holding that Golding review was unavailable for Petitioner’s ineffective assistance claim because that claim did not arise out of the actions or omissions of the habeas court itself. View "Moye v. Comm’r of Corr." on Justia Law

After a jury trial, Petitioner was convicted of capital felony and arson murder, among other offenses. Petitioner sought a writ of habeas corpus alleging that his due process rights were violated because the State had failed to disclose a note written by a police detective containing details concerning the length of time that the fire burned inside the victim’s apartment prior to being discovered. First habeas counsel failed to pursue the claim, and consequently, the first habeas court rejected that claim as abandoned. Petitioner subsequently filed this habeas petition, alleging that the State withheld the evidence in violation of Brady v. Maryland and that his first habeas counsel had rendered ineffective assistance by failing to pursue and prove that claim. The second habeas court dismissed the claim. The Appellate Court remanded. The third habeas court rejected the petition. The Appellate Court reversed in part and remanded with direction to grant the petition for a writ of habeas corpus and for a new trial. The Supreme Court affirmed, holding that Petitioner was deprived of a fair trial because his rights under Brady were violated and that Petitioner’s first habeas counsel provided ineffective assistance by failing to establish that violation. View "Lapointe v. Comm’r of Corr." on Justia Law

Plaintiff brought this action pursuant to the Connecticut Fair Employment Practices Act alleging that Defendant, her employer, had engaged in sexual harassment and disability discrimination and had unlawfully terminated her on the basis of her national origin, religion, and race. The trial court granted summary judgment on all counts in favor of Defendant. The Appellate Court affirmed. The Supreme Court reversed with respect to Plaintiff’s claim of sexual harassment in the workplace and affirmed in all other respects, holding that Plaintiff established a genuine issue of material fact as to whether she was subjected to a hostile work environment on the basis of her sex. Remanded. View "Feliciano v. Autozone, Inc." on Justia Law

After a jury trial, Defendant was convicted of sexual assault in the first degree, sexual assault in the fourth degree, and risk of injury to a child. Defendant appealed, arguing that the prosecutor improperly commented on his right not to testify during her closing argument at trial. The Appellate Court affirmed. The Supreme Court affirmed, holding that the prosecutor did not engage in any impropriety and that her comments were within the constitutional limits prescribed by the Fifth Amendment. View "State v. Ruffin" on Justia Law

After a jury trial, Defendant was convicted of sexual assault in the first degree, sexual assault in the fourth degree, and risk of injury to a child. The Supreme Court affirmed, holding (1) even though Defendant was only fourteen and fifteen years old when he committed the crimes, the trial court did not err in imposing the mandatory minimum sentences for the first degree sexual assault conviction and the risk of injury conviction, as the mandatory minimum requirements left the trial court with broad discretion to fashion an appropriate sentence that accounted for Defendant’s youth and immaturity when he committed the crimes; (2) the state’s expert witness did not improperly vouch for the credibility of the victim; and (3) Defendant’s argument that the trial court improperly admitted evidence of sexual misconduct committed by Defendant when he was thirteen years old on propensity grounds was unpreserved for appeal. View "State v. Taylor G." on Justia Law

In Miller v. Alabama, the U.S. Supreme Court held that mandatory sentencing schemes that impose on juvenile offenders a term of life imprisonment without parole violate the Eighth Amendment. At issue in this case was whether a life sentence without parole may be imposed on a juvenile homicide offender in the exercise of the sentencing authority’s discretion. Defendant, who was seventeen years old at the time of the crimes leading to his convictions, was convicted of murder and other crimes. Defendant was sentenced to a total effective sentence of 100 years imprisonment, which was the functional equivalent to life without the possibility of parole. The Supreme Court reversed, holding (1) in considering whether to sentence a juvenile to a discretionary sentence of life imprisonment without the possibility of parole, the sentencer is required to take into account the factors that Miller deemed constitutionally significant before determining that such severe punishment is appropriate; and (2) in light of the uncertainty of Defendant’s sentence upon due consideration of the Miller factors, a new sentencing proceeding must be held that conforms with the dictates of Miller. View "State v. Riley" on Justia Law

After a jury trial, Defendant was convicted of one count of murder. On appeal, Defendant asserted that the trial court abused its discretion by (1) excusing a juror for injecting extraneous matters into deliberations and for refusing to deliberate; (2) excusing a second juror who was absent for one day without inquiring how long she would be unavailable; and (3) admitting into evidence testimony and a video recording relating to Defendant's refusal to cooperate with the police as they were taking a buccal swab from him. The Supreme Court affirmed, holding that the trial court did not abuse its discretion in (1) excusing the two jurors from the jury; (2) denying Defendant’s motions for a mistrial after the court excused the two jurors; and (3) admitting, as consciousness of guilt evidence, the testimony and video record of Defendant’s refusal to cooperate with the police. View "State v. Gonzalez" on Justia Law

Petitioner, an inmate at McDougall Correctional Institution, was found guilty of possession of contraband. After a hearing at which Petitioner was permitted to present witnesses and to testify on his own behalf, the Inmate Classification Administrator, ordered that Petitioner be placed in administrative segregation at Northern Correctional Institution, the state’s maximum security prison. Petitioner subsequently filed a habeas petition, which the habeas corpus denied. Petitioner appealed, arguing that the habeas court abused its discretion because it did not address his contention that his placement in administrative segregation violated his right to due process. The Appellate Court rejected Petitioner’s claims. The Supreme Court affirmed, holding (1) the Appellate Court incorrectly indicated that Connecticut prisoners can never establish a liberty interest in avoiding administrative segregation; (2) the Appellate Court incorrectly determined that the habeas court acted within its discretion in denying the petition for certification to appeal from the judgment of the habeas court because the habeas court’s reason for denying that petition was unsupportable; but (3) even if Petitioner had a liberty interest in avoiding his transfer to Northern, he received all of the process he was due prior to that transfer. View "Vandever v. Comm’r of Corr." on Justia Law

After a jury trial, Defendant was convicted of burglary in the first degree and kidnapping in the first degree. The Appellate Court vacated Defendant’s conviction and ordered a hearing to determine whether a competency evaluation was required, determining that the trial court had violated Defendant’s right to due process by failing to conduct a proper inquiry into Defendant’s competency. The Supreme Court affirmed, holding (1) the Appellate Court properly determined that the trial court’s independent inquiry into Defendant’s request for a competency evaluation was inadequate; (2) under the specific facts of this case, it was an abuse of the trial court’s discretion not to order a competency hearing; and (3) the remedy ordered by the Appellate Court was in line with United States Supreme Court precedent. Remanded. View "State v. Dort" on Justia Law