Justia Connecticut Supreme Court Opinion Summaries
Articles Posted in Civil Rights
State v. Komisarjevsky
The Supreme Court affirmed the judgment of the trial court convicting Defendant of six counts of capital felony, among other crimes, holding that Connecticut's individual voir dire process protected Defendant's right to a fair trial by assessing and mitigating the prejudicial effects of pretrial publicity about this notorious case.The State charged Defendant with six counts of capital felony, three counts of murder, four counts of kidnapping, and other crimes. Following extensive pretrial motions practice, Defendant's case was tried to a jury, which returned a guilty verdict on all counts. The trial court subsequently sentenced Defendant to six consecutive death sentences. On appeal, Defendant claimed, among other allegations of error, that the trial court improperly denied his motion to change the venue of his trial given the effects of prejudicial pretrial publicity. The Supreme Court affirmed, holding (1) the pretrial publicity did not result in actual jury prejudice that deprived Defendant of a fair trial; and (2) Defendant was not entitled to relief on his remaining allegations of error. View "State v. Komisarjevsky" on Justia Law
State v. Davis
The Supreme Court remanded this case to the trial court for further proceedings, holding that the trial court erred by failing to inquire into defense counsel's alleged conflict of interest.Defendant was convicted of one count of murder and sentenced to fifty years of imprisonment. On appeal, Defendant argued that his federal constitutional right to the effective assistance of counsel was violated during trial when the court denied his motions to dismiss his counsel without adequately inquiring into certain bases for his motions and when the court failed to conduct any inquiry into defense counsel's alleged conflict of interest. The Supreme Court affirmed, holding that the trial court inadequately inquired into the bases for Defendant's motions to dismiss defense counsel. View "State v. Davis" on Justia Law
Moore v. Commissioner of Correction
The Supreme Court affirmed the judgment of the appellate court dismissing Petitioner's appeal from the judgment of the habeas court denying Petitioner's petition for a writ of habeas corpus, holding that Petitioner could not prevail on his claim of ineffective assistance of trial counsel.Petitioner was convicted of robbery in the first degree. Later, Petitioner filed a petition for a writ of habeas corpus, asserting that he had received ineffective assistance of counsel during plea negotiations prior to his trial. The appellate court dismissed the petition. The Supreme Court affirmed, holding that Petitioner failed to meet his burden of proving that his attorney did not adequately advise him of his maximum sentencing exposure if convicted of the lesser included offense of robbery in the third degree. View "Moore v. Commissioner of Correction" on Justia Law
State v. Gonzalez
The Supreme Court affirmed the decision of the appellate court affirming the judgment of the trial court convicting Defendant of three counts of sexual assault in the first degree and other crimes, holding that neither the structure nor the content of the prosecutor's closing argument deprived Defendant of his constitutional rights.On appeal, Defendant argued that the prosecutor deprived him of his constitutional rights to present a closing argument and to a fair trial by reserving her analysis of certain evidence for the rebuttal portion of closing argument and by mischaracterizing other evidence during rebuttal. The appellate court affirmed. The Supreme Court affirmed, holding that Defendant's claims of prosecutorial impropriety failed. View "State v. Gonzalez" on Justia Law
Ross v. Commissioner of Correction
The Supreme Court affirmed the judgment of the appellate court, which affirmed the judgment of the habeas court denying Petitioner's amended petition for a writ of habeas corpus, holding that Petitioner failed to demonstrate that he was prejudiced by his trial counsel's failure to object to the prosecutor's improper comments during closing argument at Petitioner's criminal trial.Petitioner was convicted of murder. On appeal, the appellate court concluded that at least one of the prosecutor's comments during closing argument violated Petitioner's constitutional right to a fair trial but that Petitioner had not been prejudiced by the improper remarks. The Supreme Court affirmed, holding that the failure to Petitioner's criminal trial counsel to object to the prosecutor's improper remarks did not undermine the Court's confidence in the verdict. View "Ross v. Commissioner of Correction" on Justia Law
Ross v. Commissioner of Correction
The Supreme Court affirmed the judgment of the appellate court denying habeas corpus relief after concluding that the doctrine of collateral estoppel barred Petitioner from litigating the issue of whether he was prejudiced he was prejudiced by his counsel's failure to object to the prosecutor's improper comments during closing argument at his criminal trial, holding that Petitioner failed to demonstrate prejudice.Petitioner, who was convicted of murder, filed a petition for a writ of habeas corpus alleging that his criminal trial counsel rendered ineffective assistance by, among other things, failing to object to the prosecutor's improper remarks during closing argument. The court denied the petition, concluding that Petitioner had failed to demonstrate that he had suffered prejudice. The appellate court affirmed on the grounds that Petitioner was collaterally estopped from litigating the issue of prejudice. The Supreme Court affirmed, holding (1) the doctrine of collateral estoppel did not apply; and (2) Petitioner failed to demonstrate prejudice from his counsel's performance. View "Ross v. Commissioner of Correction" on Justia Law
State v. Imperiale
The Supreme Court affirmed the judgment of the trial court revoking Defendant's probation and sentencing him to a two-year term of imprisonment, holding that the trial court did not improperly deny Defendant's motion to dismiss the violation of probation charge.On appeal, Defendant argued that the condition of probation upon which the violation of probation charged was predicated violated his Fourteenth Amendment rights to due process and equal protection as well as the Eighth Amendment prohibition against the imposition of cruel and unusual punishment. The Supreme Court affirmed, holding that Defendant's claims on appeal failed. View "State v. Imperiale" on Justia Law
State v. Angel M.
The Supreme Court affirmed Defendant's conviction of the sexual assault of a twelve-year-old girl and his sentence of thirty-three years, holding that the trial court's enhancement of Defendant's sentence was not fundamentally unfair.On appeal, Defendant argued that, at sentencing, the trial court violated his due process right by penalizing him for refusing to apologize for his criminal misconduct. Specifically, Defendant argued that his sentence contravened his constitutional right against self-incrimination because an apology would necessarily have required him to admit guilt. The Appellate Court affirmed, concluding that there was no evidentiary support for Defendant's contention that the trial court had increased his sentence because of his unwillingness to apologize to the victims. The Supreme Court affirmed, holding that the Appellate Court properly concluded that the trial court did not penalize Defendant for maintaining his innocence at sentencing. View "State v. Angel M." on Justia Law
State v. Espino
The Supreme Court reversed the judgment of conviction rendered by the trial court following Defendant's conditional plea of nolo contendere to the charge of possession of a controlled substance with intent to sell, holding that the trial court erred in denying Defendant's motion to suppress.On appeal, Defendant argued that she was illegally detained, along with her codefendant, in a car in the parking lot of a multiunit apartment building because the police lacked either a warrant or a reasonable, articulable suspicion of criminal activity. The Supreme Court reversed, holding that Defendant's detention was not permissible under the exception to the Fourth Amendment's warrant requirement articulated in Michigan v. Summers, 452 U.S. 692, and Bailey v. United States, 568 U.S. 186 (2013) because Defendant was not within the "immediate vicinity" of the apartment to be searched. View "State v. Espino" on Justia Law
State v. Rolon
The Supreme Court reversed the judgment of conviction rendered by the trial court following Defendant's conditional plea of nolo contendere to the charge of possession of a controlled substance with intent to sell, holding that the trial court erred in denying Defendant's motion to suppress.Defendant sought to suppress evidence seized after his warrantless detention in the parking lot of a multiunit apartment building. The trial court denied the suppression motion. The Supreme Court reversed, holding that Defendant was not an "occupant" within the "immediate vicinity" of the premises subject to a search warrant under the exception to the Fourth Amendment's warrant requirement set forth in Michigan v. Summers, 452 U.S. 692 (1981), and Bailey v. United States, 568 U.S. 186 (2013). View "State v. Rolon" on Justia Law