Justia Connecticut Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the trial court convicting Defendant of employing a minor in an obscene performance in violation of Conn. Gen. Stat. 53a-196a, sexual assault in the first degree, and other offenses, holding that Defendant was not entitled to relief on his claims of error.Specifically, the Supreme Court held (1) the trial court did not abuse its discretion in denying Defendant's motion to sever the sexual offenses with the nonsexual offenses and in joining the informations for trial; (2) the obscene performance statute was not unconstitutionally vague as applied to Defendant's conduct, and the First Amendment did not require the Court to undertake an independent appellate review of that conviction; (3) the trial court's potentially incorrect rulings, including those relating to the excludion from evidence video recordings of forensic interviews of the victim, were harmless error beyond a reasonable doubt; and (4) the evidence was sufficient to support Defendant's convictions of assault in the third degree, criminal violation of a protective order, and stalking in the first degree. View "State v. Michael R." on Justia Law

The Supreme Court answered a certified question of law concerning the applicability of Conn. Gen. Stat. 53-37 to this case, concluding that section 53-37 did not apply because Plaintiff's complaint did not allege any speech constituting an "advertisement."Plaintiff brought this reenforcement action challenging 53-37, which provides that "[a]ny person who, by his advertisement, ridicules or holds up to contempt any person or class of persons, on account of the creed, religion, color, denomination, nationality or race of such person or class of persons, shall be guilty of a class D misdemeanor." Plaintiff alleged that the statue violated his right to free speech under the First and Fourteenth Amendments to the United States Constitution and sought declaratory and injunctive relief seeking permanently to enjoin the enforcement of the statute. Defendants filed a motion to dismiss for lack of subject matter jurisdiction, arguing that Plaintiff lacked standing to bring the action because he had failed to allege an injury in fact. The Supreme Court answered a certified question regarding the issue by answering that the uncontroverted evidence demonstrated that section 53-37 was not intended to encompass the type of personal, noncommercial speech alleged in Plaintiff's complaint. View "Cerame v. Lamont" on Justia Law

The Supreme Court reversed the judgment of the appellate court reversing Defendant's conviction following her conditional plea of nolo contendere to the charge of possession of narcotics with intent to sell, holding that the appellate court incorrectly determined that the trial court erred by denying Defendant's motion to suppress.On appeal, Defendant argued that the trial court erred in denying her motion to suppress evidence seized by the police following a warrantless entry into her apartment on the grounds that the exigent circumstances and emergency aid doctrines supported the warrantless search of her apartment. The appellate court agreed and reversed. The Supreme Court reversed, holding (1) the warrantless entry was supported by the exigent circumstances doctrine; and (2) the evidence supported an objectively reasonable belief that someone inside Defendant's apartment was in need of emergency medical aid. View "State v. Curet" on Justia Law

The Supreme Court reversed Defendant's conviction for two counts of aggravated sexual assault of a minor and two counts of risk of injury to a child, holding that the trial court improperly failed to order that certain material be turned over to the defense and that the error was not harmless beyond a reasonable doubt.On appeal, Defendant argued, among other things, that the trial court violated his Sixth Amendment right to confrontation by not ordering disclosure of the victims' psychiatric records to the defense. The Supreme Court agreed, holding that the trial court (1) committed harmful error by failing to order that exculpatory and relevant impeachment material contained in the victims' psychiatric records be turned over to the defense; (2) improperly precluded cross-examination of the mothers of the victims concerning their U visa applications; and (3) improperly instructed the jury. View "State v. Juan A. G.-P." on Justia Law

The Supreme Court dismissed this appeal stemming from the COVID-19 pandemic and the controversy over whether a mandate should be implemented requiring the state's schoolchildren to wear masks while in school, holding that this Court lacked jurisdiction.In June 2020, the state Department of Education, the state Commissioner of Education, and the Governor (collectively, Defendants) undertook to mandate that schoolchildren wear masks in school. Plaintiffs brought this lawsuit challenging the legality of Defendants' school mask mandate and seeking declaratory and injunctive relief. The Supreme Court granted summary judgment for Defendant, concluding that Plaintiffs were not entitled to relief. Plaintiffs appealed. The Supreme Court dismissed the appeal, holding that because the Department repealed the school mask mandate while this appeal was pending, the appeal was moot. View "Conn. Freedom Alliance, LLC v. Dep't of Education" on Justia Law

The Supreme Court affirmed the judgment of the trial court denying Defendant's motion to suppress statements he had made during two separately recorded interrogations of him by police officers, holding that the trial court properly denied Defendant's motion to suppress.The two interrogations at issue occurred on the same day. As to the first interrogation, Defendant claimed that the police failed to advise him of his rights pursuant to Miranda v. Arizona, 384 U.S. 436 (1966). Defendant further claimed that the second interrogation was tainted by the alleged illegality of the first interrogation. The trial court denied the motion to suppress and, following a jury trial, convicted Defendant of manslaughter in the first degree with a firearm. The Supreme Court affirmed, holding (1) Miranda warnings were not required for the first interrogation because it was not custodial; and (2) the failure to provide the warnings did not taint the second interrogation. View "State v. Brandon" on Justia Law

The Supreme Court affirmed the judgment of the habeas court denying Petitioner's petition for a writ of habeas corpus, holding that Petitioner failed to establish that he was entitled to relief.Petitioner was convicted of manslaughter in the first degree with a firearm, assault in the first degree, and criminal possession of a firearm. In his habeas petition, Petitioner argued that his trial counsel's concession of Petitioner's guilt to the manslaughter charge without Petitioner's prior approval violated his rights to effective assistance of counsel under Strickland v. Washington, 466 U.S. 668 (1984), and personal autonomy under McCoy v. Louisiana, __ U.S. __ (2018). The habeas court denied the petition, finding Petitioner's claims to be without merit. The Supreme Court affirmed, holding (1) the habeas court correctly determined that Petitioner's right to autonomy was not implicated under the facts of this case; and (2) Petitioner's second claim on appeal was unpreserved. View "Grant v. Commissioner of Correction" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of felony murder, with robbery in the third degree as the predicate felony and carrying a pistol or revolver without a permit, holding that Defendant was not entitled to relief on his allegations of error.On appeal, Defendant argued, among other things, that the prosecutor committed improprieties during closing argument by arguing facts that were not in evidence and by making inferences that were unsupported by the evidence. The Supreme Court affirmed, holding (1) there was sufficient evidence to support the conviction of felony murder with the predicate felony of third-degree robbery; and (2) the prosecutor did not engage in improprieties during closing argument that deprived Defendant of his due process right to a fair trial. View "State v. Brown" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of two counts each of sexual assault in the first degree and unlawful restraint in the first degree and one count of assault in the second degree, holding that Defendant's claims on appeal failed.On appeal, Defendant argued, among other things, that the trial court violated his rights under the Confrontation Clause of the Sixth Amendment to the United States Constitution. The Supreme Court affirmed, holding (1) the trial court violated Defendant's Sixth Amendment rights under State v. Walker, 212 A.3d 1244 (Conn. 2019), by admitting certain testimony, but the violation was harmless under State v. Golding, 567 A.2d 832 (Conn. 1989); (2) Defendant failed to prove a violation of his constitutional right to due process; and (3) the trial court did not abuse its discretion in denying either Defendant's supplemental motion for a new trial or his motion for a new trial. View "State v. Johnson" on Justia Law

The Supreme Court affirmed Defendant's conviction, rendered after a jury trial, of one count each of felony murder, conspiracy to commit robbery in the first degree, and carrying a pistol without a permit, holding that Defendant was not entitled to relief on his claims of error.Specifically, the Supreme Court held (1) under the circumstances of the case, the trial court did not abuse its discretion when it admitted a dual inculpatory statement under section 8-6(4) of the Connecticut Code of Evidence; (2) the statement at issue was non-testimonial, and its admission at trial did not violate Defendant's Sixth Amendment right to confrontation; (3) certain statements made by the prosecutor did not violate Defendant's right to confrontation under the state Constitution; and (4) Defendant was not entitled to relief on his second claim of impropriety. View "State v. Graham" on Justia Law