Justia Connecticut Supreme Court Opinion Summaries

The Supreme Court reversed the judgment of the appellate court reversing the judgments of the trial court revoking Defendant's probation pursuant to Conn. Gen. Stat. 53a.32, holding that Defendant's conduct leading to the revocation was not entitled to First Amendment protection.After an escalated emotional confrontation with the staff of his child's preschool the trial court found that the State had met its burden of proving, by a preponderance of the evidence, that Defendant had violated the standard terms of his probation by violating Conn. Gen. Stat. 53a-181(a). On appeal, Defendant argued that his remarks warranted First Amendment protection because the State's evidence was insufficient to establish that his remarks constituted a true threat. The appellate court agreed and reversed. The Supreme Court reversed, holding that the appellate court erred in concluding that Defendant's remarks warranted First Amendment protection. View "State v. Taveras" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of sexual assault in the first and fourth degree, attempt to commit sexual assault in the first degree, and two counts of risk of injury to a child, holding that there was no error in the proceedings below.On appeal, Defendant argued (1) the trial court erred in overruling his objection brought pursuant to Batson v. Kentucky, 476 U.S. 79 (1986), objecting to the prosecutor's exercise of peremptory challenges to two prospective members of the jury; and (2) his conviction for risk of injury to a child violated constitutional double jeopardy protections. The Supreme Court affirmed, holding (1) the trial court did not commit clear error in determining that Defendant failed to meet his burden of proving by a preponderance of the evidence that the jury selection process in his case was tainted by purposeful discrimination; and (2) Defendant's conviction for two counts of risk of injury did not violate his right to be free from double jeopardy. View "State v. Jose A.B." on Justia Law

The Supreme Court affirmed the judgment of the appellate court concluding that Defendant's confrontation rights were not violated by the admission into evidence of a codefendant's dual inculpatory statement to a fellow inmate acting at the behest of the state police, holding that there was no error.Defendant was convicted by a jury of murder, home invasion, burglary, and other crimes. The appellate court affirmed. At issue before the Supreme Court was whether the appellate court correctly concluded that the admission of the codefendant's dual inculpatory statement did not violate Defendant's confrontation rights under either the United States or Connecticut constitutions. The Supreme Court affirmed, holding that there was no error in the proceedings below. View "State v. Patel" on Justia Law

The Supreme Court reversed the judgment of the trial court dismissing the appeal of the decision of the Commission on Human Rights and Opportunities finding that Defendants - Edge Fitness and Club Fitness - did not engage in discriminatory public accommodations practices, holding that there is no implied gender privacy exception to Conn. Gen. Stat. 46a-64, the Public Accommodation Act.The trial court concluded that women's only workout areas in otherwise public gyms did not violate section 46a-64. The Supreme Court reversed, holding (1) the exceptions to the general prohibition against discrimination on the basis of sex in public accommodations are limited to those expressly provided by the plain language of section 46a-64; and (2) Defendants' gyms were places of public accommodation that denied the complainants full and equal accommodations on the basis of their sex. View "Commission on Human Rights & Opportunities v. Edge Fitness, LLC" on Justia Law

The Supreme Court reversed the judgment of the trial court denying Defendant's motion to correct an illegal sentence, holding that the trial court abused its discretion by denying Defendant's motion to correct.Defendant, a juvenile offender, was convicted of two counts each of kidnapping in the first degree and sexual assault in the first degree, among other offenses. The sentencing court imposed a total effective sentence of sixty years of incarceration. Relying on later changes to juvenile sentencing law, Defendant filed a motion to correct an illegal sentence. The trial court rejected Defendant's claims. The Supreme Court reversed, holding (1) the sentencing court substantially relied on a materially false and unreliable theory; and (2) therefore, Defendant's sentence was imposed in an illegal manner in violation of his right to due process, and the trial court erred in denying Defendant's motion to correct. View "State v. Belcher" on Justia Law

The Supreme Court affirmed the judgment of the appellate court affirming the trial court's judgments following Defendant's conditional pleas of nolo contendere to charges of sale of a controlled substance and violation of probation, holding that Defendant could not meet the requirements to establish classical aggrievement.On appeal, Defendant, who was Caucasian, argued that his conviction violated his right to due process because the statute under which he was convicted violates the Equal Protection Clause of the United States Constitution because it was enacted to discriminate against African Americans and Mexican Americans. The appellate court affirmed, ruling that Defendant could not bring his constitutional challenge in his individual capacity based on the alleged violation of others' equal protection rights. The Supreme Court affirmed, holding that Defendant failed to meet the requirements to establish classical aggrievement. View "State v. Bradley" on Justia Law

The Supreme Court reversed the judgment of the appellate court affirming Defendant's conviction, holding that the warrantless canine sniff conducted by law enforcement officers of the exterior door to a motel room for the purpose of detecting the presence of illegal drugs inside the room violated the warrant requirement of Conn. Const. Art. I, 7.After Defendant was charged with several drug-related offenses he filed a motion to suppress the evidence that had been seized from his motel room pursuant to a search warrant. The trial court denied the motion. Thereafter, Defendant entered a conditional plea of solo contenders. The appellate court affirmed. The Supreme Court reversed, holding that the appellate court erred in concluding (1) the canine sniff was not a search that violated Defendant's rights under article 1, section 7; and (2) the visual sweep of Defendant's motel room was justified by the exigencies of the situation. The Court remanded the case for further proceedings. View "State v. Correa" on Justia Law

The Supreme Court affirmed the judgment of the appellate court concluding that the trial court's instructions in this criminal case, while improper, did not impact Defendant's due process right to a fair trial, holding that the appellate court did not err.Defendant was convicted of three counts of robbery in the first degree, two counts of felony murder, and other offenses for her involvement in two murders. The appellate court affirmed, holding that the trial court's instructions on robbery and felony murder were improper but provided the jury with a legally valid but factually unsupported basis for finding Defendant guilty. The Supreme Court affirmed, holding (1) the trial court's instructions provided the jury with a legally valid and factually supported alternative basis for finding Defendant guilty of robbery and felony murder; and (2) therefore, Defendant could not establish that the trial court's error more probably than not affected the jury's verdict. View "State v. Turner" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of felony murder, robbery in the first degree, conspiracy to commit robbery in the first degree, and criminal possession of a firearm, holding that Defendant's claims on appeal were unavailing.On appeal, Defendant argued that the trial court improperly admitted portions of a written statement from one of the state's witnesses and unduly restricted the cross-examination of another state witness. The Supreme Court affirmed, holding (1) Defendant failed to demonstrate that the admission of the witness's written statement substantially swayed the jury's verdict; and (2) assuming that partial restrictions placed on defense counsel's cross-examination of the second witness infringed on the minimum of cross-examination guaranteed by the Confrontation Clause of the Sixth Amendment, such infringement was harmless beyond a reasonable doubt. View "State v. Gibson" on Justia Law

The Supreme Court reversed in part the judgment of the trial court finding Defendant guilty of manslaughter in the first degree with a firearm and other offenses, holding that the trial court improperly admitted certain evidence.On appeal, Defendant argued that his statements to the police were improperly admitted into evidence because his constitutional rights were violated when the police continued to question him after he invoked his right to counsel pursuant to Miranda v. Arizona, 384 U.S. 436 (1966). Defendant further argued that the prosecutor committed improprieties during closing argument, depriving him of his right to a fair trial. The Supreme Court affirmed, holding (1) the admission of Defendant's written statement and a portion of a video recording of the interview with police should have been suppressed, and the error was not harmless as to Defendant's conviction of manslaughter in the first degree with a firearm; and (2) there was no other reversible error in this case. View "State v. Culbreath" on Justia Law