Justia Connecticut Supreme Court Opinion SummariesArticles Posted in Constitutional Law
State v. Patrick M.
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
State v. Hinds
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
Diaz v. Commissioner of Correction
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
State v. Smith
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
State v. Bowden
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
State v. Samuolis
The Supreme Court affirmed Defendant's convictions of murder, assault in the first degree by means of the discharge of a firearm, and attempt to commit assault in the first degree by means of the discharge of a firearm, holding that there was no violation of Defendant's Fourth Amendment rights in this case.On appeal, Defendant argued that the trial court erred in denying his motion to suppress evidence seized from his father on the grounds that the police officers' warrantless entry into the residence home under the emergency exception to the Fourth Amendment warrant requirement was justified. Alternatively, the court deterred that, even if the initial entry was unlawful, Defendant's shooting of the victim sufficiently attenuated that unlawful act from the subsequent lawful search and seizure of the evidence at issue. The Supreme Court affirmed, holding that (1) under the totality of the circumstances, it was objectively reasonable for the officers to conclude that there was an emergency justifying their initial entry into the residence; and (2) in light of this conclusion, the subsequent entries were similarly justified. View "State v. Samuolis" on Justia Law
In re Vada V.
The Supreme Court affirmed the judgments of the trial court terminating Parents' parental rights pursuant to Conn. Gen. Stat. 17a-112(j), holding that Parents were not entitled to relief on their three unpreserved constitutional claims relating to the virtual nature of the termination of parental rights trial.On appeal, Parents argued (1) the trial court violated their rights under Conn. Const. art. I, 10 and art. V, 1 by conducting the termination trial virtually rather than in person; (2) the trial court violated their constitutional right to due process by denying them the right to physically confront and cross-examine the witnesses against them at the virtual trial; and (3) the constitutional rights were violated when the trial court did not provide them with their own exclusive devices and internet connection to participate both visually and by audio in the trial. The Supreme Court affirmed, holding that Parents were not entitled to relief on their unpreserved claims of error. View "In re Vada V." on Justia Law
In re Annessa J.
The Supreme Court reversed the judgment of the appellate court insofar as that court reversed the trial court's rulings on Parents' motions for posttermination visitation and affirmed the judgment insofar as the appellate court upheld the trial court's termination of Parent's parental rights, holding that the trial court correctly articulated the proper standard.The appellate court reversed the trial court's denial of Parents' posttermination visitation motions on the ground that the trial court applied an incorrect legal standard in considering these motions. The Supreme Court reversed in part, holding that the appellate court (1) correctly concluded that Mother failed to establish that there exists a fundamental right under the Connecticut Constitution to an in-person termination of parental rights trial; and (2) improperly reversed the trial court's rulings on Parents' motions for failing to comply with the standard set forth in In re Ava W., 248 A.3d 675 (Conn. 2020), for deciding motions for posttermination visitation. View "In re Annessa J." on Justia Law
State v. Hargett
The Supreme Court affirmed the judgment of the appellate court affirming the trial court's judgment convicting Defendant of one count of murder, holding that Defendant was not entitled to relief on any of his allegations on appeal.Specifically, the Supreme Court held that the appellate court correctly concluded that the trial court (1) did not violate Defendant's Sixth Amendment right to present a defense by excluding from evidence a statement purportedly made by an unknown female bystander and an autopsy toxicology report; (2) did not violate Defendant's right to due process by declining to give a jury instruction on self-defense; and (3) did not abuse its discretion by declining to sanction the state for its late disclosure of the murder weapon and related expert reports by excluding this evidence or dismissing the murder charge. The Court further cautioned the State regarding the late disclosure of evidence. View "State v. Hargett" on Justia Law
Barlow v. Commissioner of Correction
The Supreme Court affirmed the judgment of the habeas court granting Petitioner's petition for writ of habeas corpus after determining that Petitioner had suffered prejudice as a result of the ineffective assistance of his trial counsel, holding that there was no error.In granting habeas relief, the habeas court determined that Petitioner's trial counsel failed to provide Petitioner with professional advise and assistance during pretrial plea negotiations and that Petitioner would have accepted the trial court's pretrial plea offer but for the ineffective assistance of Petitioner's trial counsel. The Supreme Court affirmed, holding that the habeas court did not err in concluding that Petitioner had fulfilled his burden of establishing prejudice. View "Barlow v. Commissioner of Correction" on Justia Law