Justia Connecticut Supreme Court Opinion Summaries

Defendant Rafael Crespo was convicted of one count of assault in the third degree and two counts of sexual assault in the first degree. Defendant's conviction stemmed from allegations that he had forcibly engaged in sexual intercourse with the victim and physically assaulted her on several occasions during their relationship. The appellate court affirmed. After analyzing the case under State v. Golding the Supreme Court affirmed, holding that the trial court properly excluded impeachment evidence regarding the victim's prior sexual conduct and that the exclusion of this evidence did not clearly violate Defendant's constitutional rights to confrontation and to present a defense. View "State v. Crespo" on Justia Law

After a jury trial, Defendant Leotis Payne was convicted of, inter alia, felony murder, robbery in the first degree, and attempt to tamper with a juror. The Supreme Court affirmed, holding (1) the trial court improperly joined for trial the felony murder and jury tampering cases against the Defendant for trial, but the error was harmless; (2) the trial court improperly admitted the testimony of one of the state's witnesses regarding an alleged threat made by Defendant, but the error was harmless; and (3) three statements by the prosecutor during closing and rebuttal arguments were improper, but those improprieties did not deprive Defendant of a fair trial, and therefore, Defendant was not entitled to a new trial due to the prosecutorial improprieties. In affirming the judgments of the trial court, the Court also overruled State v. King and its progeny, which recognized a presumption in favor of joinder in criminal cases. View "State v. Payne" on Justia Law

Defendant Osibisa Hall pleaded guilty to one count of possession of marijuana with intent to sell and two counts of violation of a protective order. Defendant subsequently filed a motion to withdraw his guilty pleas and vacate the judgments of conviction, claiming that the trial court did not fulfill its obligation to address him personally and determine that he understood the immigration consequences of his pleas. The court denied the motion. The appellate court reversed, finding that the trial court failed to comply substantially with Conn. Gen. Stat. 54-1j when it neglected to personally address Defendant regarding the potential immigration consequences of his pleas. The Supreme Court reversed the appellate court, holding (1) substantial compliance with section 54-1j can be established even if the court does not address the defendant personally; and (2) the trial court substantially complied with section 54-1j in the present case. View "State v. Hall" on Justia Law

In an underlying employment dispute, Employee sued Employer for discrimination. After the jury issued a verdict in favor of Defendant, Plaintiff moved for a new trial, alleging that Defendant had engaged in discovery misconduct. The trial court denied Plaintiff's motion. The appellate court affirmed. At issue before the Supreme Court was whether a party seeking a new trial on the basis of alleged knowing and deliberate discovery misconduct must show that the result at a new trial would likely be different. The Supreme Court affirmed, holding that the rule set forth in Varley v. Varley to determine whether a new trial should be granted on the basis of allegations that the judgment was obtained through fraud, as reframed in this decision, applies to motions for a new trial based on the discovery misconduct of the nonmoving party. View "Duart v. Dep't of Corr." on Justia Law

After a jury trial, Defendant Darryl W. was convicted of criminal attempt to commit aggravated sexual assault in the first degree, sexual assault in the third degree and kidnapping in the first degree with a firearm. The trial court also found Defendant guilty of violation of probation based on his conviction of the criminal offenses. The Supreme Court affirmed the judgments of the trial court, holding (1) Defendant failed to preserve his claims that the court improperly instructed the jury regarding the elements of aggravated sexual assault in the first degree and kidnapping in the first degree with a firearm and regarding his affirmative defense to kidnapping in the first degree with a firearm; and (2) certain comments by the senior assistant state's attorney during closing argument did not constitute prosecutorial impropriety. View "State v. Darryl W." on Justia Law

After a jury trial, Defendant Herman Apodaca was convicted of felony murder, conspiracy to commit robbery in the first degree, and robbery in the first degree. The Supreme Court affirmed, holding (1) trial court properly dismissed a juror midtrial for cause; (2) the trial court properly instructed the juror on the felony murder count; (3) under the facts of the case, the court did not violate its obligations by declining to rephrase the entire conspiracy instruction in laypersons' terms after the jury requested further instructions; and (4) the trial court's instructions on conspiracy to commit robbery were not misleading, and therefore, Defendant's due process rights were not violated by the instructions. View "State v. Apodaca" on Justia Law

Defendant Alia Altajir pleaded nolo contendere to charges of misconduct with a motor vehicle. The trial court imposed a sentence of five years' incarceration, suspended after one year, and five years of probation. Defendant later violated the special conditions of her probation. At a subsequent dispositional hearing, the trial court admitted undated photographs gathered from Facebook, on which Defendant maintained a profile. Defendant appealed, arguing that the trial court had violated her right to due process by admitting the photographs. The appellate court determined that this claim was unpreserved and did not merit review. The Supreme Court affirmed on the ground that the photographs satisfied the minimum standard of reliability constitutionally required to admit evidence at the dispositional phase of a probation revocation hearing. View "State v. Altajir" on Justia Law

Defendants, an attorney and a law firm, represented Plaintiff Robert Grimm in an action to dissolve Grimm's marriage. Plaintiff subsequently brought a legal malpractice action against Defendants. The trial court granted Defendants' motion for judgment because Plaintiff had not disclosed an expert when one was required and, therefore, could not establish a prima facie case for legal malpractice as to Defendants' breach of the standard of care. The Supreme Court affirmed the judgment of the trial court, holding that the trial court did not abuse its discretion in (1) determining that the critical statements concerning Defendants made by the Court in its opinion affirming the underlying divorce action were not sufficient expert evidence of Defendants' malpractice; and (2) considering Defendants' motion for judgment the day after the motion was filed and the day before jury selection began in order to avoid the delay and expense of a trial in which Plaintiff could not present any evidence to support his claim. View "Grimm v. Fox" on Justia Law

After a jury trial, Defendant was convicted of several crimes. The trial court enhanced Defendant's sentence for being a persistent dangerous felony offender in violation of Conn. Gen. Stat. 53a-40. On appeal, the Supreme Court concluded that section 53a-40(h) was unconstitutional to the extent it required the trial court to make the requisite finding that Defendant's extended incarceration would best serve the public interest. On remand, the jury found that extended incarceration of Defendant would best serve the public interest, and the trial court again imposed an enhanced sentence pursuant to section 53a-40. The Supreme Court affirmed, holding that the trial court did not err in (1) denying Defendant's motion to dismiss the information because the retroactive application to Defendant of section 53a-40(h), as modified by the constitutional gloss that the Court placed on it before remand, did not violate the ex post facto clause of the Fourteenth Amendment; (2) construing the term "public interest," as used in section 53a-40(h), to exclude consideration of the costs of incarceration; (3) precluding Defendant from introducing expert testimony about his anticipated release date from a concurrent federal sentence; and (4) admitting evidence of the details of the victim's injuries. View "State v. Bell" on Justia Law

Defendant pleaded guilty to murder and capital felony and was sentenced to death. The case was remanded for a new penalty phase hearing, during which Defendant waived his right to have a jury determine his sentence. After the hearing, a three-judge panel again sentenced Defendant to death. The Supreme Court affirmed the sentence, holding (1) Defendant's waiver of a jury for the penalty phase hearing was constitutionally valid; (2) the presiding judge at the penalty phase hearing did not make comments that warranted recusal, and his involvement in earlier proceedings did not give rise to an improper appearance of impartiality; (3) Defendant failed to establish that the absence of a specific intent requirement in the aggravating factor found by the panel rendered his death sentence unconstitutional; (4) the evidence was sufficient to support the panel's finding of an aggravating factor; (5) the panel properly weighed aggravating and mitigating factors and determined that death was the appropriate punishment; (6) Defendant failed to establish that his sentence was the product of passion, prejudice and other arbitrary factors; and (7) the death penalty, as a general matter, does not violate the state constitution. View "State v. Rizzo" on Justia Law