Justia Connecticut Supreme Court Opinion Summaries

Articles Posted in Constitutional Law
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The Supreme Court dismissed this appeal stemming from the COVID-19 pandemic and the controversy over whether a mandate should be implemented requiring the state's schoolchildren to wear masks while in school, holding that this Court lacked jurisdiction.In June 2020, the state Department of Education, the state Commissioner of Education, and the Governor (collectively, Defendants) undertook to mandate that schoolchildren wear masks in school. Plaintiffs brought this lawsuit challenging the legality of Defendants' school mask mandate and seeking declaratory and injunctive relief. The Supreme Court granted summary judgment for Defendant, concluding that Plaintiffs were not entitled to relief. Plaintiffs appealed. The Supreme Court dismissed the appeal, holding that because the Department repealed the school mask mandate while this appeal was pending, the appeal was moot. View "Conn. Freedom Alliance, LLC v. Dep't of Education" on Justia Law

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The Supreme Court affirmed the judgment of the habeas court denying Petitioner's petition for a writ of habeas corpus, holding that Petitioner failed to establish that he was entitled to relief.Petitioner was convicted of manslaughter in the first degree with a firearm, assault in the first degree, and criminal possession of a firearm. In his habeas petition, Petitioner argued that his trial counsel's concession of Petitioner's guilt to the manslaughter charge without Petitioner's prior approval violated his rights to effective assistance of counsel under Strickland v. Washington, 466 U.S. 668 (1984), and personal autonomy under McCoy v. Louisiana, __ U.S. __ (2018). The habeas court denied the petition, finding Petitioner's claims to be without merit. The Supreme Court affirmed, holding (1) the habeas court correctly determined that Petitioner's right to autonomy was not implicated under the facts of this case; and (2) Petitioner's second claim on appeal was unpreserved. View "Grant v. Commissioner of Correction" on Justia Law

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The Supreme Court affirmed the judgment of the trial court convicting Defendant of two counts each of sexual assault in the first degree and unlawful restraint in the first degree and one count of assault in the second degree, holding that Defendant's claims on appeal failed.On appeal, Defendant argued, among other things, that the trial court violated his rights under the Confrontation Clause of the Sixth Amendment to the United States Constitution. The Supreme Court affirmed, holding (1) the trial court violated Defendant's Sixth Amendment rights under State v. Walker, 212 A.3d 1244 (Conn. 2019), by admitting certain testimony, but the violation was harmless under State v. Golding, 567 A.2d 832 (Conn. 1989); (2) Defendant failed to prove a violation of his constitutional right to due process; and (3) the trial court did not abuse its discretion in denying either Defendant's supplemental motion for a new trial or his motion for a new trial. View "State v. Johnson" on Justia Law

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The Supreme Court affirmed the judgment of the appellate court affirming Defendant's conviction of three counts of custodial interference in the second degree, holding that Conn. Gen. Stat. 53a-98(a)(3) is not unconstitutionally vague as applied to Defendant and that there was sufficient evidence to support the conviction.On appeal, Defendant argued that section 53a-98(a)(3) is unconstitutionally vague in its application to her and that there was insufficient evidence to support her conviction. The appellate court rejected both claims. The Supreme Court affirmed, holding that the appellate court correctly concluded that section 53a-98(a)(3) was not unconstitutionally vague in its application to her and that the evidence was sufficient to support Defendant's conviction of three counts of custodial interference in the second degree. View "State v. Lori T." on Justia Law

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The Supreme Court affirmed Defendant's conviction, rendered after a jury trial, of one count each of felony murder, conspiracy to commit robbery in the first degree, and carrying a pistol without a permit, holding that Defendant was not entitled to relief on his claims of error.Specifically, the Supreme Court held (1) under the circumstances of the case, the trial court did not abuse its discretion when it admitted a dual inculpatory statement under section 8-6(4) of the Connecticut Code of Evidence; (2) the statement at issue was non-testimonial, and its admission at trial did not violate Defendant's Sixth Amendment right to confrontation; (3) certain statements made by the prosecutor did not violate Defendant's right to confrontation under the state Constitution; and (4) Defendant was not entitled to relief on his second claim of impropriety. View "State v. Graham" on Justia Law

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The Supreme Court reversed Defendant's conviction of murder and criminal possession of a firearm in connection with the death of his wife, holding that the prosecutor improperly commented on Defendant's invocation of his right to remain silent following his arrest and advisement of rights pursuant to Miranda v. Arizona, 384 U.S. 436, 384 U.S. 436 (1966).On appeal, Defendant argued that the evidence was insufficient to establish his identity as the perpetrator of the crimes of conviction and that the prosecutor improperly commented on his post-Miranda silence. The Supreme Court reversed his convictions, holding (1) the evidence was sufficient to support the conviction; but (2) the prosecutor's remarks impermissibly used Defendant's post-Miranda silence against him, in violation of Doyle v. Ohio, 426 U.S. 610 (1976), rendering the trial "fundamentally unfair," and the error was not harmless. View "State v. Patrick M." on Justia Law

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The Supreme Court affirmed Defendant's conviction of murder and carrying a dangerous weapon, holding that there was no deprivation of Defendant's due process right to a fair trial in this case.On appeal, Defendant argued that the prosecutor committed two instances of impropriety during the State's closing and rebuttal arguments, neither of which the defense objected to at trial. The Supreme Court upheld Defendant's convictions, holding (1) the first challenged argument did not exceed the bounds of permissible argument; and (2) as to the prosecutor's second challenged argument, even if the prosecutor's remarks were improper, there was no possibility that they deprived Defendant of a fair trial. View "State v. Hinds" on Justia Law

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The Supreme Court reversed the judgment of the appellate court dismissing Petitioner's appeal from the judgment of the habeas court denying his petition for a writ of habeas corpus, holding that Petitioner failed to prove his claim that his counsel labored under an actual conflict of interest.At issue was whether the habeas court abused its discretion in denying Petitioner's petition for certification to appeal with respect to his claim that his defense counsel rendered ineffective assistance during his second criminal trial by simultaneously working as defense counsel and as an active duty police officer in a different city, which Petitioner claimed was a conflict of interest. The Supreme Court affirmed, holding that defense counsel's actions did not rise to the level of an actual conflict of interest for purposes of the Sixth Amendment. View "Diaz v. Commissioner of Correction" on Justia Law

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The Supreme Court affirmed in part and reversed in part the judgment of the trial convicting Defendant of various crimes arising from five criminal cases, which included first degree robbery, second degree arson, and attempt to commit murder, holding that the trial court erred in denying Defendant's motion to suppress.At issue on appeal was the trial court's denial of Defendant's motion to suppress evidence discovered during a search of his cell phone and evidence obtained from his cell phone service provider. Specifically in question was whether the warrants authorizing those searches were supported by probable cause and whether they particularly described the place to be searched and the things to be seized. The Supreme Court reversed in part, holding (1) the trial court erred in denying Defendant's motion to suppress the information obtained from the execution of both warrants; and (2) this error was harmless with respect to some, but not all, of the crimes alleged in the indictment. View "State v. Smith" on Justia Law

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The Supreme Court affirmed the judgment of the trial court convicting Defendant of felony murder, robbery in the first degree, and other crimes, holding that any error in the trial court's failure to suppress evidence obtained from a search warrant was harmless.On appeal, Defendant challenged the trial court's denial of his motion to suppress evidence obtained from a search of his cell phone, arguing that the application for the warrant authorizing the search lacked a particular description of the items to be seized and that the affidavit supporting the application failed to establish probable cause. The Supreme Court affirmed, holding that the State met its burden of showing that any error in the denial of Defendant's motion to suppress was harmless beyond a reasonable doubt. View "State v. Bowden" on Justia Law