Justia Connecticut Supreme Court Opinion Summaries

The Supreme Court affirmed in part and reversed in part the judgment of the Appellate Court affirming Defendant's conviction of two counts of assault in the first degree as a principal and two counts of assault in the first degree as an accessory, holding that the Appellate Court erred insofar as it affirmed Defendant's assault conviction as to Kenneth Tucker.Defendant's convictions were based on a joint physical assault involving two perpetrators, Defendant and his brother, and two victims, Kenneth Tucker and Luis Rodriguez. On appeal, Defendant argued that his conviction of four assault violated his right to be free from double jeopardy under the federal constitution because he committed only one assault per victim, for a total of two assaults. The Supreme Court reversed the Appellate Court's judgment insofar as it affirmed Defendant's conviction as to Tucker, holding (1) the imposition of multiple punishments on Defendant for Tucker's assault violated the Double Jeopardy Clause; and (2) Defendant's criminal acts involving Rodriguez constituted two distinct courses of conduct for double jeopardy purposes. View "State v. Ruiz-Pacheco" on Justia Law

The Supreme Court reversed the judgment of the Appellate Court affirming the judgment of the habeas court denying Petitioner's second petition for a writ of habeas corpus, holding that Petitioner's federal due process rights were violated when the State knowingly failed to correct the false testimony of two prosecution witnesses when defense counsel was aware of the falsity of the testimony.A jury found Petitioner and his codefendants guilty of murder and conspiracy to commit murder. In his second petition for a writ of habeas corpus Petitioner alleged that his prior habeas counsel provided ineffective assistance in that he failed to raise the claim that the State had violated Petitioner's right to due process by failing to correct the allegedly false testimony of two witnesses at trial. The habeas court denied the petition, and the Appellate Court affirmed. The Supreme Court reversed, holding that, in light of the facts of this case, the fact that counsel was aware of the falsity of the testimony was insufficient to protect Petitioner's due process rights. View "Gomez v. Commissioner of Correction" on Justia Law

The Supreme Court reversed the judgment of the Appellate Court affirming the judgment of the habeas court denying Petitioner's amended petition for a writ of habeas corpus, holding that the Appellate Court improperly raised and decided the unpreserved issue of waiver without first providing the parties with an opportunity to be heard on that issue.Petitioner pled guilty under the Alford doctrine to one count of home invasion. Thereafter, Petitioner commenced this habeas action alleging that his trial counsel had provided ineffective assistance by failing to file a motion to discuss the home invasion charge. The habeas court denied the petition. The Appellate Court affirmed on an alternative ground, concluding that Petitioner waived his ineffective assistance claim by virtue of the entry and acceptance of his Alford plea. The Supreme Court reversed and remanded the case, holding that because the parties were not provided an opportunity to be heard on waiver it was improper for the Appellate Court to raise and decide that issue. View "Diaz v. Commissioner of Correction" on Justia Law

The Supreme Court affirmed the judgment of the trial court denying Defendant's motion to suppress photographs and videos of suspected child pornography that the police recovered from computer equipment and other media storage seized from Defendant's residence pursuant to a search warrant, holding that the search warrant affidavit supported a finding of probable cause.On appeal, Defendant argued that the search warrant was not supported by probable cause because the issuing judge could not reasonably have inferred from descriptions in the affidavit of two photographs of nude children that the photographs were lascivious. The Supreme Court affirmed, holding that the totality of the circumstances described in the affidavit and the reasonable inferences drawn therefore supported a finding of probable cause to believe that a there was a substantial chance that a search of Defendant's residence would uncover evidence of possession of child pornography. The Court further declined Defendant's invitation to adopt a more demanding standard for assessing whether there is probable cause to issue a search warrant. View "State v. Sawyer" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of murder, conspiracy to commit murder, and related crimes, holding that any violation of Defendant's right to confrontation was harmless and that the trial court's third-party culpability instruction was sufficient.Defendant's convictions arose from a shooting on a crowded street in which a fifteen-year-old boy died and two individuals were seriously injured. The Supreme Court affirmed the convictions, holding (1) as to Defendant's argument that the trial court erred in admitting the out-of-court statements of two witnesses identifying Defendant as the shooter, Defendant failed to preserve his hearsay objection, and even if the admission of the out-of-court identifications violated Defendant's right to confrontation, any error was harmless beyond a reasonable doubt; and (2) the trial court's third-party culpability instruction was sufficient despite the fact that the instruction omitted certain names. View "State v. Edwards" on Justia Law

The Supreme Court reversed the judgment of the Appellate Court affirming Defendant's judgment of conviction and remanded the case for a new trial, holding that the admission of certain testimony during trial violated Defendant's constitutional right of confrontation.Defendant was convicted of felony murder and related crimes. Defendant appealed, arguing that the testimony of two witnesses was improperly admitted under the Connecticut Code of Evidence and the confrontation clause of the Sixth Amendment. The Appellate Court affirmed. The Supreme Court reversed, holding (1) the former testimony of one of the witnesses was improperly admitted because the State failed to demonstrate that Defendant was unavailable within the meaning of the confrontation clause because the State failed to establish that it undertook a reasonable, diligent, and good faith effort to locate the witness prior to Defendant's trial; and (2) the admission of the testimony of the other witness was constitutional. View "State v. Lebrick" on Justia Law

The Supreme Court affirmed the judgment of the Appellate Court affirming the judgment of conviction of felony murder, attempt to commit robbery, and other offenses, holding that Defendant was not harmed when the State, after granting immunity to three witnesses for testimony given during the State's case-in-chief, revoked that immunity when the same witnesses later testified in the defense case-in-chief.On appeal, Defendant argued that his constitutional rights to due process, a fair trial compulsory process, and to present a defense were violated when the trial court improperly permitted the State to revoke the immunity of the three witnesses at issue in this case, causing them to invoke their Fifth Amendment right against self-incrimination. The Supreme Court affirmed, holding (1) Defendant failed to establish that, by revoking the witnesses' immunity, the State violated Defendant's constitutional rights; and (2) there was no other prejudicial error. View "State v. Collymore" on Justia Law

The Supreme Court affirmed the judgment of the Appellate Court concluding that the record was inadequate to review Defendant's challenge under Batson v. Kentucky, 476 U.S. 79 (1986), to the prosecutor's exercise of a peremptory challenge on a prospective juror, holding that the trial court did not commit clear error in finding that the prosecutor did not engage in purposeful discrimination when he peremptorily challenged the juror.Defendant was convicted of assault in the first degree as an accessory and conspiracy to commit assault in the first degree. On appeal, Defendant challenged the prosecutor's exercise of a peremptory challenge on a prospective juror on the basis of his employment history. The record, however, did not indicate the race or ethnicity of both the prospective juror and one of the two jurors whom Defendant pinpointed as examples of disparate treatment by the prosecutor. The Appellate Court affirmed. The Supreme Court affirmed, holding that the Appellate Court's well reasoned opinion fully addressed and properly resolved the certified issue. View "State v. Raynor" on Justia Law

The Supreme Court affirmed the judgment of the Appellate Court upholding Defendant's conviction of felony murder on the basis of its rejection of his claim brought under Batson v. Kentucky, 476 U.S. 79 (1986), holding that that the Appellate Court properly affirmed the judgment of conviction but systemic concerns about Batson's failure to address the effects of implicit bias and disparate impact must be referred to a Jury Selection Task Force.Defendant was convicted of felony murder. The Appellate Division affirmed, holding (1) there was no adequate claim that the Appellate Court improperly upheld the trial court's finding that the prosecutor's reasons were not pretextual under the third step of Batson; and (2) although the relief the Court could provide was constrained by Defendant's decision to limit his Batson claims to the Equal Protection Clause, the broader themes of disparate impact and implicit bias that Defendant advanced raised enough concern with the fairness of the criminal justice system for measures to be concerned intended to promote the selection of diverse jury panels in the state's courthouses. View "State v. Holmes" on Justia Law

The Supreme Court affirmed the judgment of the Appellate Court affirming the judgment of the trial court denying Defendant's motion to suppress evidence of a firearm that police seized during an investigatory stop, holding that the patdown of Defendant was supported by reasonable and articulable suspicion.Defendant entered a conditional plea of solo contenders to one count of carrying a pistol without a permit and one count of criminal possession of a pistol or revolver. The Appellate Court affirmed the judgment of the trial court denying Defendant's motion to suppress, holding that the trial court properly concluded that the patdown of Defendant was supported by reasonable and articulable suspicion that he might be dangerous. The Supreme Court affirmed, holding that the Appellate Court correctly concluded that the trial court properly determined that the patdown of Defendant was lawful under both the federal and state constitutions. View "State v. Lewis" on Justia Law