Justia Connecticut Supreme Court Opinion Summaries

The Supreme Court reversed the judgment of the appellate court affirming Defendant's conviction of robbery in the first degree following the entry of his conditional plea of nolo contendere, holding that the prosecution of Defendant was time barred by the five-year statute of limitations set forth in Conn. Gen. Stat. 54-193(b).The robbery in this place took place on November 29, 2013. The next day, Defendant confessed to a detective as to his involvement in the robbery. On December 6, 2018, Defendant was transported to the superior court, where he was served with an arrest warrant. Defendant filed a motion to dismiss, arguing that the prosecution was barred under section 54-193(b). The trial court denied the motion to dismiss, finding that the State made at least some effort to execute the warrant on or before November 29, 2018. After Defendant entered his nolo contendere plea he appealed the denial of his motion to dismiss. The appellate court affirmed. The Supreme Court reversed, holding that the State did not meet its burden to demonstrate that the warrant for Defendant's arrest was executed without unreasonable delay. View "State v. Freeman" on Justia Law

The Supreme Court reversed the judgment of the appellate court dismissing Petitioner's appeal from the judgment of the habeas court denying his petition for a writ of habeas corpus, holding that Petitioner failed to prove his claim that his counsel labored under an actual conflict of interest.At issue was whether the habeas court abused its discretion in denying Petitioner's petition for certification to appeal with respect to his claim that his defense counsel rendered ineffective assistance during his second criminal trial by simultaneously working as defense counsel and as an active duty police officer in a different city, which Petitioner claimed was a conflict of interest. The Supreme Court affirmed, holding that defense counsel's actions did not rise to the level of an actual conflict of interest for purposes of the Sixth Amendment. View "Diaz v. Commissioner of Correction" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the trial convicting Defendant of various crimes arising from five criminal cases, which included first degree robbery, second degree arson, and attempt to commit murder, holding that the trial court erred in denying Defendant's motion to suppress.At issue on appeal was the trial court's denial of Defendant's motion to suppress evidence discovered during a search of his cell phone and evidence obtained from his cell phone service provider. Specifically in question was whether the warrants authorizing those searches were supported by probable cause and whether they particularly described the place to be searched and the things to be seized. The Supreme Court reversed in part, holding (1) the trial court erred in denying Defendant's motion to suppress the information obtained from the execution of both warrants; and (2) this error was harmless with respect to some, but not all, of the crimes alleged in the indictment. View "State v. Smith" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of felony murder, robbery in the first degree, and other crimes, holding that any error in the trial court's failure to suppress evidence obtained from a search warrant was harmless.On appeal, Defendant challenged the trial court's denial of his motion to suppress evidence obtained from a search of his cell phone, arguing that the application for the warrant authorizing the search lacked a particular description of the items to be seized and that the affidavit supporting the application failed to establish probable cause. The Supreme Court affirmed, holding that the State met its burden of showing that any error in the denial of Defendant's motion to suppress was harmless beyond a reasonable doubt. View "State v. Bowden" on Justia Law

The Supreme Court affirmed Defendant's convictions of murder, assault in the first degree by means of the discharge of a firearm, and attempt to commit assault in the first degree by means of the discharge of a firearm, holding that there was no violation of Defendant's Fourth Amendment rights in this case.On appeal, Defendant argued that the trial court erred in denying his motion to suppress evidence seized from his father on the grounds that the police officers' warrantless entry into the residence home under the emergency exception to the Fourth Amendment warrant requirement was justified. Alternatively, the court deterred that, even if the initial entry was unlawful, Defendant's shooting of the victim sufficiently attenuated that unlawful act from the subsequent lawful search and seizure of the evidence at issue. The Supreme Court affirmed, holding that (1) under the totality of the circumstances, it was objectively reasonable for the officers to conclude that there was an emergency justifying their initial entry into the residence; and (2) in light of this conclusion, the subsequent entries were similarly justified. View "State v. Samuolis" on Justia Law

The Supreme Court affirmed the judgment of the appellate court affirming the trial court's judgment convicting Defendant of one count of murder, holding that Defendant was not entitled to relief on any of his allegations on appeal.Specifically, the Supreme Court held that the appellate court correctly concluded that the trial court (1) did not violate Defendant's Sixth Amendment right to present a defense by excluding from evidence a statement purportedly made by an unknown female bystander and an autopsy toxicology report; (2) did not violate Defendant's right to due process by declining to give a jury instruction on self-defense; and (3) did not abuse its discretion by declining to sanction the state for its late disclosure of the murder weapon and related expert reports by excluding this evidence or dismissing the murder charge. The Court further cautioned the State regarding the late disclosure of evidence. View "State v. Hargett" on Justia Law

The Supreme Court affirmed the judgment of the habeas court granting Petitioner's petition for writ of habeas corpus after determining that Petitioner had suffered prejudice as a result of the ineffective assistance of his trial counsel, holding that there was no error.In granting habeas relief, the habeas court determined that Petitioner's trial counsel failed to provide Petitioner with professional advise and assistance during pretrial plea negotiations and that Petitioner would have accepted the trial court's pretrial plea offer but for the ineffective assistance of Petitioner's trial counsel. The Supreme Court affirmed, holding that the habeas court did not err in concluding that Petitioner had fulfilled his burden of establishing prejudice. View "Barlow v. Commissioner of Correction" on Justia Law

The Supreme Court reversed the judgment of the trial court accepting Defendant's plea of nolo contendere to robbery in the first degree and assault in the first degree and sentencing Defendant to an aggregate sentence of ten years' imprisonment, holding that a John Doe arrest warrant was invalid and could not commence prosecution for purposes of satisfying the statute of limitations.On appeal, Defendant argued that the John Doe arrest warrant that identified the suspect on the basis of a general physical description and several mixed partial DNA profiles to which the suspect may not have been a contributor and that did not state the probability that a random person would match any of the profiles did not satisfy the particularity requirement of the Fourth Amendment for purposes of commencing a prosecution within the applicable statute of limitations. The Supreme Court agreed, holding that, to satisfy the Fourth Amendment's particularity requirement, the affidavit accompanying a John Doe DNA arrest warrant application must contain information assuring the judicial authority issuing the warrant that the DNA profile identifies the person responsible for the crime on the basis of his or her unique DNA profile and should include information as to the statistical rarity of that DNA profile. View "State v. Police" on Justia Law

The Supreme Court exercised its supervisory authority to require that a trial court either canvass the defendant or, in certain circumstances, inquire of defense counsel directly to determine whether the defendant was properly advised regarding the waiver of his right to testify.Defendant was convicted of one count of sexual assault in the first degree following a jury trial at which he did not testify. On appeal, Defendant argued that defense counsel's representation that Defendant had waived his right to testify was insufficient to constitute a waiver of that right. The Supreme Court affirmed, holding (1) the constitution does not require that a defendant personally assert the waiver of his constitutional right to testify on the record; but (2) an on-the-record canvass of a defendant is the best practice to ensure that the defendant's waiver of his right to testify is made knowingly, intelligently and voluntarily. View "State v. Morel-Vargas" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of murder and carrying a pistol without a permit, holding that there was no error or abuse of discretion in the proceedings below.On appeal, Defendant argued that the trial court abused its discretion in excluding evidence of an assault of one of the state's witnesses and that the trial court erred by preventing him from impeaching another witness with evidence of previous criminal offenses. The Supreme Court affirmed, holding (1) the trial court's exclusion of evidence related to the assault did not violate Defendant's constitutional rights to present a defense and to confront the witnesses against him; and (2) the trial court did not violate Defendant's constitutional right to confrontation or the rules of evidence by preventing him from impeaching the witness with evidence of certain prior criminal convictions. View "State v. Torres" on Justia Law