Justia Connecticut Supreme Court Opinion Summaries

A municipal tax collector initiated a bank execution action against an individual to collect unpaid personal property taxes owed by a business with which the individual was previously associated. The individual had moved to California years earlier and claimed that she never received notice of the tax debt or an opportunity to contest it, despite providing her new address to the tax collector. Previous bank executions had been initiated, but the individual continued to assert lack of notice. In the 2021 action, the trial court found that the tax collector failed to comply with statutory notice requirements and that the individual had not been afforded due process, leading the court to grant her exemption from the execution.Following the 2021 judgment, the tax collector withdrew its appeal and attempted a new bank execution after sending written demand to the individual's California address, but did not provide a new tax bill or opportunity to challenge it. The individual again moved for exemption. The Superior Court concluded that the new execution was a collateral attack on the previous judgment and was barred by doctrines of res judicata and collateral estoppel. The Appellate Court affirmed, finding that the issue of notice and opportunity to challenge the tax debt had been actually litigated and necessarily determined in the prior action.Upon review, the Connecticut Supreme Court held that collateral estoppel barred the municipal tax collector from relitigating whether it could execute on the individual's funds without first providing adequate notice and an opportunity to challenge the underlying tax debt. The Court determined that both independent, alternative grounds supporting the earlier judgment were entitled to preclusive effect and declined to create a public policy exception for municipal tax collection actions. The Supreme Court affirmed the judgment of the Appellate Court. View "Torrington Tax Collector, LLC v. Riley" on Justia Law

The defendant was charged with multiple counts of sexual assault in the first degree and risk of injury to a child, stemming from multiple incidents of sexual abuse against two minor victims who attended an in-home day care operated by the defendant’s wife in New Haven. The alleged abuse occurred between 2007 and 2012, when the victims were approximately three to eight years old. Each count of sexual assault was predicated on multiple, separate instances of specific sexual acts committed by the defendant. Following police investigations in 2019 and subsequent arrest in 2020, the defendant was tried on these charges.At trial in the Superior Court for the judicial district of New Haven, the prosecution presented evidence of several distinct incidents of sexual abuse. The trial judge provided the jury with a specific unanimity instruction for each count, requiring jurors to unanimously agree that the defendant committed at least one specific instance of the charged conduct in order to find him guilty on any particular count. The jury found the defendant guilty on all counts of sexual assault and risk of injury to a child, and the court sentenced him to a total effective sentence of twenty-five years, with execution suspended after twenty-one years and ten years of probation.On direct appeal to the Connecticut Supreme Court, the defendant argued that his federal constitutional right to a unanimous jury verdict was violated because the trial court did not require the jury to answer special interrogatories regarding unanimity on each alleged incident, despite providing proper unanimity instructions. The Connecticut Supreme Court held that the constitution does not require special interrogatories in addition to specific unanimity instructions for counts charging multiple instances of conduct. The court affirmed the judgments of conviction. View "State v. Carlos G." on Justia Law

The defendant was charged with criminal possession of a firearm or ammunition and criminal violation of a protective order. These charges stemmed from two prior cases involving allegations of sexual assault in the fourth degree and risk of injury to a child, both concerning a minor family member. In each prior case, the Superior Court issued protective orders requiring the defendant to surrender firearms and ammunition. In 2022, the defendant was arrested for allegedly possessing firearms or ammunition in violation of those protective orders.After the 2022 arrest, the defendant moved to dismiss the new charges, arguing that the protective orders were not issued "in a case involving the use, attempted use or threatened use of physical force" as required by Connecticut General Statutes § 53a-217(a)(4)(A), since the underlying offenses did not explicitly include use of physical force as an element. The Superior Court denied the motion to dismiss. The defendant then entered a conditional plea of nolo contendere to one count each of criminal possession of a firearm or ammunition and criminal violation of a protective order. The state entered a nolle prosequi as to the remaining charges. The defendant appealed, and the case was transferred from the Appellate Court to the Connecticut Supreme Court.The Connecticut Supreme Court affirmed the judgment. It held that the phrase "a case involving" in § 53a-217(a)(4)(A) is broadly inclusive and refers to the overall proceeding, not just the elements of the charged offense. Therefore, protective orders issued during prosecutions for sex offenses, where the use or threat of physical force or superior physical strength was present in any aspect, satisfy the statute. The court also rejected the defendant’s claim that the statute was unconstitutionally vague as applied, finding it provided sufficient guidance. Finally, the court determined that the defendant’s Second Amendment challenge to the validity of the protective orders was barred by the collateral bar rule. View "State v. Enrrique H." on Justia Law

The defendant was involved in a fatal shooting during a drug transaction in Hartford, Connecticut. He testified at trial that he acted in self-defense, claiming the victim drew a gun on him during a dispute. However, other witnesses contradicted this account, and no gun was found on or near the victim. After the shooting, the defendant fled the scene and did not report the incident to the police. He was later arrested and charged with murder.The case was tried before the Superior Court in the judicial district of Hartford. At trial, the defendant testified in his own defense. The prosecutor, with approval from the trial court, cross-examined the defendant regarding his failure to report to police that he had acted in self-defense prior to his arrest. The defense objected, arguing that the questioning infringed upon the defendant’s right to remain silent, but the trial court overruled the objection, reasoning that, by testifying, the defendant waived his Fifth Amendment right regarding silence and that his failure to report was inconsistent with a claim of self-defense. The jury found the defendant guilty of murder, and he was sentenced to fifty years in prison.On direct appeal to the Supreme Court of Connecticut, the defendant argued that the trial court committed plain error by allowing the prosecutor to cross-examine him about his prearrest silence. The Supreme Court of Connecticut held that the trial court did not commit plain error because established case law allows impeachment using a defendant’s prearrest, pre-Miranda silence, particularly when the defendant testifies and claims self-defense. The Court concluded that the circumstances did not present an obvious or egregious error requiring reversal. The judgment of conviction was affirmed. View "State v. Thorpe" on Justia Law

The case involved a fatal shooting that followed a car accident in Hartford, Connecticut. The defendant, after colliding with the victim’s vehicle, agreed to pay for the damages and arranged to meet the victim later that day. Surveillance footage and eyewitness accounts linked the defendant to the scene, describing his distinctive clothing and actions. Evidence showed the defendant met with the victim, shot him multiple times, and fled the scene. Forensic analysis detected gunshot residue on the defendant’s clothing, and cellphone data further corroborated his involvement. The defendant was subsequently arrested and charged with murder and criminal possession of a firearm.At trial in the Superior Court for the judicial district of Hartford, the jury found the defendant guilty of murder, and the court found him guilty of criminal possession of a firearm. The defendant appealed directly to the Connecticut Supreme Court, raising several unpreserved constitutional claims. He argued that his right to confrontation was violated when the State’s gunshot residue expert testified based on data and notes from a nontestifying analyst, and when the prosecutor elicited testimonial hearsay on cross-examination. He also alleged prosecutorial impropriety for introducing facts not in evidence during cross-examination.The Connecticut Supreme Court held that the claim regarding the expert’s reliance on the nontestifying analyst’s materials failed because the record was inadequate to determine whether those materials were testimonial. The court declined to adopt the State’s proposed rule barring all unpreserved confrontation claims and reaffirmed that such claims may still be reviewed if the record is sufficient. The court further held there was no confrontation clause violation or prosecutorial impropriety regarding the cross-examination, as the questions did not introduce hearsay or inadmissible evidence. The judgment of conviction was affirmed. View "State of Connecticut v. Bester" on Justia Law

A five-year-old child and her mother, recently arrived from the Dominican Republic, were staying with family in New Britain, Connecticut. The defendant, who was married to the mother's niece, lived in the same apartment. On New Year's Eve, the defendant sexually assaulted the child. Later that evening at a family party, the child told her mother that the defendant had kissed her, and after further questioning, disclosed more details of the assault. The next day, the mother confronted the defendant, who made incriminating admissions both in person and via text. Police interviewed the defendant at the station after he voluntarily agreed to meet and requested a Spanish-speaking detective. During the interview, which was conversational and not confrontational, the defendant confessed to inappropriate sexual conduct.The Superior Court, Judicial District of New Britain, denied the defendant’s pretrial motion to suppress his statements to police, finding he was not in custody for Miranda purposes. At trial, the court admitted the child’s statements to her mother under the spontaneous utterance exception to hearsay, and limited the testimony of the defense expert regarding the U visa program, which provides immigration benefits to victims of certain crimes who cooperate with law enforcement. The jury convicted the defendant of sexual assault in the first degree and risk of injury to a child.On direct appeal to the Connecticut Supreme Court, the defendant argued the trial court erred in denying his suppression motion, admitting the victim’s hearsay statements, and restricting expert testimony, and further sought review of confidential personnel records of one detective. The Connecticut Supreme Court held that the trial court properly denied the suppression motion, as the defendant was not in custody. The admission of the child’s statements was error but harmless, given other strong evidence. The limitations on the expert’s testimony did not deny due process or affect the verdict. Review of the confidential records revealed no material requiring disclosure. The conviction was affirmed. View "State of Connecticut v. Lazaro D." on Justia Law

A seventeen-year-old defendant was charged with murder after the shooting death of a victim in a Bridgeport housing complex stairwell. Surveillance footage showed the defendant leading the victim into the building and exiting alone minutes later, covering his face with a mask. The victim was later found naked and bleeding outside the basement door, having been shot six times. Police investigation led to a search of the defendant’s home, where a .45 caliber pistol and matching ammunition were found in his bedroom. The defendant, interviewed at home in the presence of his legal guardian, admitted to owning the gun and being with the victim but denied involvement in the shooting. Nineteen minutes into the interview, he invoked his right to remain silent, but questioning continued. The defendant was later located in Florida and returned to Connecticut for trial.In the Superior Court for the judicial district of Fairfield, the defendant moved to suppress statements made during the police interview, arguing he had not knowingly and voluntarily waived his Miranda rights. The court found, under the totality of the circumstances, that the waiver was valid, considering the defendant’s age, education, prior experience with law enforcement, and the presence of his guardian. The court suppressed only statements made after the defendant invoked his right to remain silent. The jury convicted the defendant of murder, and he was sentenced to forty-five years’ incarceration.On appeal to the Connecticut Supreme Court, the defendant challenged the validity of his Miranda waiver, sought greater protection under the state constitution, alleged prosecutorial impropriety, and objected to a consciousness of guilt jury instruction. The Supreme Court held that the waiver was knowing, intelligent, and voluntary, declined to adopt a rule requiring consultation with an interested adult before a juvenile’s waiver, found no prosecutorial impropriety, and determined any error in the consciousness of guilt instruction was harmless. The judgment was affirmed. View "State v. Cooper" on Justia Law

In 1984, four women in Connecticut were robbed and sexually assaulted in their homes by an unknown assailant. The perpetrator blindfolded, restrained, and threatened each victim, then stole items before leaving. Police collected physical evidence from the crime scenes, but DNA testing was not available at the time. Years later, advances in forensic science allowed the state laboratory to develop DNA profiles from the evidence, which were uploaded to the Combined DNA Index System (CODIS). In 2020, a private forensic company provided investigative leads, ultimately implicating the defendant. Police lawfully collected trash from the defendant’s residence, including a belt, and submitted it for DNA analysis without a warrant. The DNA extracted from the belt matched the crime scene profiles. Police then obtained a warrant for a confirmatory DNA sample, which further implicated the defendant.The defendant was charged in the Superior Court for the judicial district of Hartford with eight counts of kidnapping in the first degree. At trial, the court instructed the jury on the elements of kidnapping, including the factors from State v. Salamon, which help determine whether restraint exceeded what was necessary for the underlying crimes. The next day, the court provided the jury with a flowchart outlining the kidnapping elements, but the chart omitted reference to the Salamon factors. The jury found the defendant guilty on all counts, and he was sentenced to seventy-two years in prison.On appeal to the Connecticut Supreme Court, the defendant argued that the warrantless collection and analysis of his DNA from the discarded belt violated his rights under the Fourth Amendment and the Connecticut Constitution, and that the omission of the Salamon factors from the flowchart misled the jury. The Connecticut Supreme Court held that neither the collection nor the analysis of DNA from the discarded belt constituted a search under the Fourth Amendment or the state constitution when performed for identification purposes only. The court also found that the jury was not misled by the flowchart, as the full instructions included the Salamon factors and the jury was properly directed to rely on those instructions. The judgment of conviction was affirmed. View "State v. Sharpe" on Justia Law

The defendant was convicted of murder with special circumstances, home invasion, arson in the second degree, and robbery in the first degree, following a violent home invasion in Griswold, Connecticut. The crimes involved the planned theft of a gun safe and guns from the Lindquist family home, orchestrated with the help of the victims’ son, Matthew, who was later killed by the defendant and his sister, Ruth. After killing Matthew in a nearby wooded area, the defendant and Ruth entered the Lindquist home, killed Kenneth and Janet Lindquist, stole various items, and set the house on fire. The defendant’s cell phone was seized by police without a warrant after an interview, and a subsequent warrant authorized the search and seizure of “all data” from the phone, without any temporal limitations.In the Superior Court for the judicial district of New London, the defendant moved to suppress evidence obtained from his cell phone, arguing the seizure was illegal and the warrant was unconstitutional due to its broad scope. The trial court found the seizure proper and, applying the severance doctrine, limited admissible evidence to data created or received within a two-week period surrounding the crimes, suppressing data outside that window. The jury convicted the defendant on most counts, and the court vacated certain convictions before sentencing him to life imprisonment without parole.On appeal to the Connecticut Supreme Court, the defendant challenged the constitutionality of the cell phone search warrant. The Supreme Court assumed, without deciding, that the warrantless seizure was constitutional, but held that the warrant violated the Fourth Amendment’s particularity requirement because it authorized a search of all data without content or time limits. The Court further found the trial court erred in applying the severance doctrine to cure the warrant’s deficiencies. Nevertheless, the Supreme Court concluded that the error was harmless beyond a reasonable doubt, as the cell phone evidence was cumulative and the state’s case was strong without it. The judgment of conviction was affirmed. View "State v. Correa" on Justia Law

A woman was found dead in her apartment after her boyfriend, who had spent the night elsewhere, returned and discovered her body hidden in a closet. The apartment was in disarray, and drugs and a cell phone were missing. The defendant, who knew the victim and her boyfriend through drug transactions, was identified as having been at the apartment the night of the murder. Forensic evidence linked the defendant to the crime scene, including blood matching the victim on his clothing and blood matching the defendant at the scene. The defendant was arrested shortly after the murder, and additional evidence was gathered, including statements from jailhouse informants.The defendant was first convicted of murder in the Superior Court for the judicial district of New London, but the Connecticut Supreme Court reversed that conviction and ordered a new trial due to the improper admission of evidence obtained in a warrantless search. Before the second trial, the defendant requested a new probable cause hearing, which the trial court denied, reasoning that the reversal did not invalidate the original probable cause finding. The trial court also denied motions to exclude testimony from two jailhouse informants: one, who had suffered a stroke and claimed memory loss, and another whose reliability was challenged.On appeal, the Connecticut Supreme Court held that the defendant was not entitled to a second probable cause hearing after reversal and remand for a new trial, as neither the state constitution nor the relevant statute required it absent a jurisdictional defect. The court also held that admitting the prior written statement of the former cellmate did not violate the defendant’s confrontation rights, as the witness was present, took an oath, and answered questions, even if he claimed memory loss. The court further found no abuse of discretion in admitting the statement as a prior inconsistent statement or in finding the jailhouse informant’s testimony reliable. The judgment of conviction was affirmed. View "State v. Jacques" on Justia Law