Justia Connecticut Supreme Court Opinion Summaries

The State charged Defendant with murder and manslaughter in the first degree with a firearm. The jury rendered verdicts of guilty on both charges. Defendant filed a motion for judgment of acquittal and for a new trial, arguing that the verdicts were legally inconsistent. The trial court denied the motion, concluding (1) Defendant had waived the claim by failing to request a jury instruction that he could not be convicted of both charges; but (2) the verdict of guilty on the manslaughter charge must be vacated pursuant to case law because when a defendant is convicted of both a greater offense and a lesser included offense, the property remedy is to vacate the conviction on the lesser included offense. The Supreme Court vacated both guilty verdicts, holding (1) legally inconsistent verdicts involve jury error that may be raised for the first time after the verdicts have been returned or on appeal, and therefore, the trial court erred in determining that Defendant had waived his claims that the guilty verdicts were legally inconsistent; and (2) the verdicts were legally inconsistent, and neither verdict can stand. Remanded for a new trial. View "State v. Chyung" on Justia Law

After a jury trial, Defendant was convicted of murder. On appeal, Defendant’s principal claim was that the trial court violated his constitutional right to present a defense by refusing either to issue a summons to secure the attendance of a material witness in support of a theory of third-party culpability or to allow Defendant to introduce that witness’ statement to the police in lieu of her live testimony. The Supreme Court affirmed, holding (1) regarding Defendant’s argument regarding the issuance of a summons for the witness, defense counsel’s failure to locate the out-of-state witness with any reasonable degree of certainty precludes relief; and (2) none of Defendant’s remaining claims warrant reversal. View "State v. Bennett" on Justia Law

Defendant pleaded nolo contendere to four count of criminal possession of a firearm. Defendant appealed, arguing that the trial court erred in denying his motion to suppress certain evidence discovered following the execution of a search warrant at his house because the warrant was issued without a showing of probable cause. The Supreme Court affirmed the judgment of the trial court, holding that, on he basis of the Court’s review of the search warrant affidavit in its entirety, the trial court properly found that the facts submitted were sufficient to support a finding of probable cause. View "State v. Holley" on Justia Law

After a jury trial, Defendant was convicted of sexual assault in the first degree and other offenses. The trial court rendered judgment in accordance with the jury’s verdict. The Appellate Court reversed the judgment and remanded the case for a new trial, holding that the State deprived Defendant of his constitutional right to remain silent when the prosecutor noted twice during closing arguments that Defendant had not testified in his own defense. The Supreme Court affirmed, holding (1) the prosecutor’s two statements clearly violated Defendant’s Fifth Amendment right to remain silent; and (2) the State failed to meet its burden of proof that the prosecutor’s comments were harmless beyond a reasonable doubt. View "State v. A. M." on Justia Law

Defendant lived in a unit of a multiunit condominium complex. When the police department received an anonymous tip that Defendant was boasting about growing marijuana in his unit, the police entered the building with a drug dog and conducted a directed search in which the dog sniffed at the common floor hallways and at the bottom of the door to Defendant’s unit. The officers later returned with a search warrant, and Defendant was subsequently arrested and charged with several drug offenses and illegal possession of an assault weapon. Defendant filed a motion to suppress, arguing that the canine sniff of the threshold of his unit for the purpose of investigating the unit’s contents constituted a search within the meaning of article first, section seven of the Connecticut Constitution and the Fourth Amendment of the United States Constitution. The trial court granted the motion to suppress, concluding that the canine sniff constituted a search within the meaning of the Fourth Amendment and, therefore, required a warrant predicated on probable cause. The Supreme Court affirmed, holding that a canine sniff directed toward a home is a search under article first, section seven of the Connecticut Constitution and, as such, requires a warrant issued upon a court’s finding of probable cause. View "State v. Kono" on Justia Law

Plaintiffs were four bus companies operating buses over routes in and around the cities of New Britian and Hartford. Each plaintiff had authority to operate a bus service over a specific route pursuant to a certificate of public convenience and necessity. When a new busway was constructed by the state, the state sought to hire new companies to operate buses over the routes Plaintiffs currently operate. In a separate action, Plaintiffs sought to enjoin the Commissioner of Transportation from transferring the routes at issue to new operators. While that case was pending, the Commissioner condemned the certificates pursuant to the State’s power of eminent domain. Plaintiff filed the actions that were the subject of this appeal, claiming that the Commissioner lacked the statutory authority to condemn their certificates. The trial court consolidated the actions and granted the Commissioner’s motion for summary judgment, concluding that Conn. Gen. Stat. 13b-36(a) gave the Commissioner authority to condemn the certificates. The Supreme Court reversed, holding that the legislature did not intend for the term “facilities” in the statute to refer to intangible operating rights reflected in the certificates at issue. View "Dattco, Inc. v. Commissioner of Transportation" on Justia Law

Defendant was charged with murder and other offenses. In 2010, the trial court found Defendant incompetent to stand trial. Thereafter, a judge found that Defendant had been restored to competency and granted his motion to represent himself. In 2015, the trial court again found Defendant incompetent to stand trial. After evidentiary hearings, the trial court granted the State’s motion for forcible medication of Defendant, finding that the State had established that forced medication would not violate Defendant’s federal due process rights under the test set forth by the United States Supreme Court in Sell v. United States. The Supreme Court affirmed, holding that the trial court correctly determined that forced medication was “substantially likely” to render Defendant competent to stand trial. View "State v. Wang" on Justia Law

Defendant entered a conditional plea of nolo contendere to possession of narcotics with intent to sell and failure to appear in the first degree. Defendant appealed, arguing that the trial court erred in denying Defendant’s motion to suppress narcotics evidence. The appellate court affirmed, concluding (1) the trial court correctly determined that Defendant was not seized until police officers performed a patdown search for weapons, and (2) the record was inadequate to review Defendant’s claim that he was unreasonably seized when two police cruisers descended upon him in a small parking lot and an officer verbally commanded him to stop. The Supreme Court reversed, holding (1) the appellate court erred in concluding that Defendant was not seized until the officers patted him down for weapons and that certain of Defendant's claims in that regard were unreviewable; and (2) the evidence Defendant sought to suppress was seized in violation of the federal and state constitutions. View "State v. Edmonds" on Justia Law

Pursuant to a plea agreement, Petitioner pleaded guilty to one count of possession of a controlled substance with intent to sell. After Petitioner was released from custody, federal authorities entered a final order of removal based on Petitioner’s felony conviction. Petitioner filed a habeas corpus petition claiming that his trial counsel’s assistance was deficient because counsel failed to advise him of the immigration consequences of his guilty plea, as required by Padilla v. Kentucky. The habeas court granted the petition and ordered that Petitioner’s conviction be vacated, holding that counsel was required to inform Petitioner that his plea of guilty to an aggravated felony made him subject to mandatory deportation. The State appealed, arguing that Padilla requires only that counsel advise a client of a heightened risk of deportation, not that federal law mandates deportation. The Supreme Court affirmed, holding that, because federal law called for deportation for Petitioner’s conviction, counsel was required to unequivocally convey to Petitioner that federal law mandated deportation as the consequence for pleading guilty. View "Budziszewski v. Comm’r of Corr." on Justia Law

Defendant was charged with several offenses after shooting Albert Weibel during an attempted robbery. Before trial, Defendant moved to preclude Weibel from making an in-court identification of Defendant, arguing that in-court identification procedures are unnecessarily suggestive. The trial court denied the motion pursuant to State v. Smith. During trial, Weibel identified Defendant as his assailant. The jury subsequently found Defendant guilty of conspiracy to commit robbery in the first degree and assault in the first degree. The Appellate Court affirmed. Defendant appealed, arguing that the Supreme Court should overrule the holding in Smith and hold that inherently suggestive in-court identifications are inadmissible even in the absence of a suggestive pretrial identification procedure. The Supreme Court affirmed, holding (1) first time in-court identifications must be prescreened for admissibility by the trial court; (2) Weibel’s in-court identification was a first time in-court identification and should have been prescreened, and the failure to follow the procedures outlined in this opinion potentially violated Defendant’s due process rights; but (3) any due process violation was harmless beyond a reasonable doubt. View "State v. Dickson" on Justia Law