Justia Connecticut Supreme Court Opinion Summaries

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

In 1997, an individual diagnosed with schizophrenia and alcohol use disorder attacked his father, resulting in serious injuries. He was charged with several offenses, including attempted murder and first-degree assault. At trial, he was found not guilty by reason of mental disease or defect and was committed to the custody of the Psychiatric Security Review Board for up to twenty years. Over the years, his commitment was extended multiple times, sometimes by agreement and sometimes after evidentiary hearings, based on findings that he remained a danger to himself or others. His condition improved over time, leading to less restrictive placements and eventual conditional release into the community, though he experienced a setback in 2020 that led to brief rehospitalization.After the expiration of his initial commitment, the state repeatedly sought and obtained extensions of his commitment. In 2022, the state filed another petition to extend his commitment. The acquittee moved to dismiss, arguing that the statutory commitment procedure violated his constitutional right to equal protection. The Superior Court, Judicial District of Middlesex, denied the motion and, after a hearing, found clear and convincing evidence that he remained dangerous, extending his commitment for two more years, until March 2025. The acquittee appealed, and the Connecticut Supreme Court granted transfer of the appeal.While the appeal was pending, the state filed a new petition to extend the commitment beyond 2025. The Board, however, found the acquittee was no longer dangerous and recommended denial of the petition. The state withdrew its petition, resulting in the acquittee’s discharge in March 2025. The Connecticut Supreme Court held that the appeal was moot because the acquittee had been released and no practical relief could be granted. The Court found neither the collateral consequences doctrine nor the “capable of repetition, yet evading review” exception applied. However, to avoid any lingering effects, the Court vacated the 2023 commitment order. View "State v. Guild" on Justia Law

A man was found not guilty by reason of mental disease or defect for several violent offenses, including first-degree burglary, risk of injury to a child, third-degree assault, and possession of a weapon on school grounds. He was committed to the jurisdiction of the Psychiatric Security Review Board in 2003 for up to ten years. His commitment was extended several times by agreement, but in 2018, he was granted conditional release and began living in the community under strict conditions related to his mental health treatment. In 2019, the state petitioned to extend his commitment, arguing that his discharge would pose a danger to himself or others.The Superior Court, judicial district of Stamford-Norwalk, denied the acquittee’s motion to dismiss the petition, which had argued that the recommitment procedure violated his federal equal protection rights. The court found, by clear and convincing evidence, that he continued to suffer from a psychiatric illness and posed a danger if released without supervision, and extended his commitment. The Appellate Court affirmed, holding that the recommitment scheme did not violate equal protection and that the trial court’s finding of dangerousness was not clearly erroneous.The Connecticut Supreme Court reviewed the case. It held that individuals found not guilty by reason of insanity and subject to recommitment are not similarly situated to civilly committed inmates for equal protection purposes, because the former’s commitment is based on a judicial finding that their criminal acts were caused by mental illness, while civilly committed inmates may develop mental illness unrelated to their criminal conduct. The Court also held that the trial court’s finding that the acquittee’s discharge would be dangerous was supported by clear and convincing evidence, given his history, the violent nature of his offenses, and the short duration of his stable conditional release. The judgment of the Appellate Court was affirmed. View "State v. Foster" on Justia Law

The defendant was convicted of murder, carrying a pistol without a permit, and criminal possession of a firearm in connection with the shooting death of the victim. The defendant appealed, claiming that the trial court deprived him of his constitutional right to present a defense by not instructing the jury on the adequacy of the police investigation. He also claimed that his due process rights were violated by admitting an out-of-court identification by an eyewitness and that his confrontation rights were violated by admitting testimony from a medical examiner who did not perform the autopsy.The trial court denied the defendant's request for an investigative inadequacy instruction, finding no evidence to support the claim that the police failed to investigate other suspects or perform a victimology. The court also denied the motion to preclude the eyewitness identification, concluding that the identification procedure was not suggestive despite the omission of one statutory instruction. The court found that the eyewitness was not pressured to make an identification and that the procedure adhered to best practices.The Connecticut Supreme Court reviewed the case and affirmed the trial court's decisions. The court held that the trial court correctly declined to instruct the jury on investigative inadequacy due to a lack of supporting evidence. The court also found that the identification procedure was not suggestive and that the eyewitness's identification was reliable. Additionally, the court concluded that the medical examiner's testimony did not violate the defendant's confrontation rights, as it was based on autopsy photographs rather than the autopsy report.The court affirmed the judgment of the trial court, finding no merit in the defendant's claims and determining that any potential errors were harmless beyond a reasonable doubt. View "State v. Villanueva" on Justia Law