Justia Connecticut Supreme Court Opinion Summaries

Defendant entered conditional pleas of nolo contendere to possession of a controlled substance with intent to sell, home invasion, robbery in the second degree, burglary in the third degree, a stealing a firearm. Defendant appealed the trial court’s denial of his motion to suppress evidence of statements he made to the police following his arrest, in which he confessed to the charged crimes. Specifically, Defendant argued that his statements should have been suppressed as the product of an illegal search because the warrant authorizing the search of his apartment was unsupported by probable cause. The Appellate Court affirmed. The Supreme Court affirmed, holding that the affidavit in support of the search warrant application established probable cause, and accordingly, the Appellate Court properly affirmed the trial court’s denial of Defendant’s motion to suppress. View "State v. Flores" on Justia Law

This case came to the Supreme Court on certification from the United States District Court for the District of Connecticut. Plaintiff sued his former employer in federal court, alleging, inter alia, that Defendants had violated Conn. Gen. Stat. 31-51q by subjecting him to discipline on account of Plaintiff’s exercise of his rights guaranteed by Conn. Const. art. I, sections 3, 4 or 14. The Supreme Court answered (1) the rule announced by the United States Supreme Court in Garcetti v. Ceballos that when employees make statements pursuant to their official duties the employees are not speaking as citizens for First Amendment purposes and the Constitution does not insulate their communications from employer discipline does not apply to a claim that an employer violated section 31-51q by subjecting an employee to discipline or discharge on account of the exercise by such an employee of rights guaranteed by Conn. Const. art. I, sections 3, 4, or 14; and (2) under the state Constitution, employee speech pursuant to official job duties on certain matters of significant public interest is protected from employer discipline in a public workplace, and section 31-51q extends the same protection to employee speech pursuant to official job duties in the private workplace. View "Trusz v. UBS Realty Investors, LLC" on Justia Law

Petitioner was convicted of reckless endangerment in the second degree and related offenses. Petitioner filed a petition for writ of habeas corpus, claiming that his trial counsel rendered ineffective assistance at his criminal trial because she chose not to pursue questioning of a potential exculpatory witness. The habeas court denied the petition. The Appellate Court dismissed Petitioner’s appeal, concluding that substantial evidence supported the habeas court’s conclusion that Petitioner had failed to establish the prejudice prong for ineffective assistance of counsel under Strickland v. Washington. The Supreme Court affirmed, holding that the Appellate Court properly dismissed Petitioner’s appeal on the ground that he had failed to satisfy the prejudice prong of Strickland. View "Staton v. Comm’r of Corr." on Justia Law

After a jury trial, Defendant was convicted of larceny in the first degree and conspiracy to commit larceny in the first degree. The convictions were based in part on evidence that included warrantless recordings of telephone conversations between Defendant and Jacqueline Becker, which were recorded without Defendant’s consent but with the consent of Becker. The Supreme Court affirmed the convictions, holding (1) recording a telephone conversation with the consent of one party to that conversation does not violate the prohibition on unreasonable searches and seizures under the Connecticut Constitution; and (2) the trial court’s failure to conduct an independent inquiry regarding Defendant’s competence to stand trial was not improper. View "State v. Skok" on Justia Law

At issue in this case was Connecticut’s debt negotiation statutes, Conn. Gen. Stat. 36a-671 through 36a-671e, which authorize the Banking Commissioner to license and regulate persons engaged in the debt negotiation. Plaintiff, a national consumer advocate law firm, petitioned the Commissioner for a declaratory ruling stating that Plaintiff qualified for exemption from the debt negotiation statutes under the attorney exception. This exception exempts only those attorneys admitted to the practice of law in Connecticut who engage or offer to engage in debt negotiation as an ancillary matter to the attorneys’ presentation of a client. The Commissioner concluded that Plaintiff did not qualify for exemption. The superior court affirmed. The Supreme Court reversed, holding that the debt negotiation statutes impermissibly intrude on the Judicial Branch’s exclusive authority to regulate attorney conduct and licensure and, therefore, violate the separation of powers provision contained in article II of the state Constitution. View "Persels & Assocs., LLC v. Banking Comm’r" on Justia Law

After a jury trial, Defendant was convicted of murder. The Supreme Court affirmed, holding (1) Defendant did not preserve his claim that the trial court had an obligation to provide, sua sponte, a jury instruction on the risk of misidentification by an eyewitness pursuant to State v. Ledbetter; (2) the trial court did not abuse its discretion in the manner in which it conducted its inquiry into the allegation of juror bias; and (3) Defendant’s exclusion from the hearing concerning possible juror bias was not a violation of his constitutional rights to be present at a critical stage of the proceedings, to counsel, and to be presumed innocent. View "State v. Dixon" on Justia Law

After a jury trial, Defendant was convicted of first degree assault, first degree unlawful restraint, and carrying a dangerous instrument. Defendant appealed, claiming that his constitutional rights to confrontation, to present a defense and to due process were violated when the trial court disclosed only four pages of the psychiatric records of E.P., a state witness, and prohibited Defendant from consulting with an expert witness as to the four disclosed pages. The Appellate Court affirmed. The Supreme Court affirmed, holding that any error in releasing only four pages of E.P.’s psychiatric records and in limiting Defendant’s ability to consult with an expert as to the disclosed pages was harmless beyond a reasonable doubt. View "State v. Santos" on Justia Law

Defendant was found guilty of capital felony and sentenced to death. While Defendant’s appeal was pending, the legislature passed Public Act 12-5, which repealed the death penalty for all crimes committed on or after April 25, 2012. On June 12, 2012, the Supreme Court affirmed Defendant’s judgment of conviction but reversed his death sentence and remanded for a new penalty phase hearing, concluding that the trial court improperly had failed to disclose to Defendant certain confidential records that were mitigating in nature. Defendant filed a motion for reconsideration, claiming that the adoption of P.A. 12-5 leads to the conclusion that capital punishment has ceased to comport with state constitutional requirements. The Supreme Court agreed and reversed Defendant’s sentence of death on the capital felony count, holding that the enactment of P.A. 12-5, when considered in light of the history of the death penalty in the state and other recent legal developments, compels the conclusion that capital punishment, as currently applied, constitutes cruel and unusual punishment in violation of the constitution of Connecticut. Remanded with direction to sentence Defendant to life imprisonment without the possibility of release. View "State v. Santiago" on Justia Law

After a hearing, the trial court terminated the parental rights of Mother as to her two minor children. Mother appealed, arguing that the trial court violated her right to due process when it failed to canvass her about her decision to waive her right to a full trial and to not contest the prosecution’s exhibits. The Appellate Court affirmed, concluding that Mother’s constitutional claim failed under the third prong of State v. Golding. Specifically, the Court concluded that, in order to prevail on an unpreserved claim under Golding, which requires that a party establish that an alleged constitutional violation “clearly exists,” a party must point to binding Connecticut precedent. The Supreme Court reversed, holding (1) the absence of existing Connecticut precedent does not preclude consideration of a claim under Golding; (2) the trial court’s failure to canvass Mother did not constitute a denial of her right to due process; but (3) the Court is warranted in using its supervisory authority over the administration of justice to impose a canvass rule requiring that a trial court canvass all parents who do not consent to the termination immediately before a parental rights termination trial, in order to ensure the overall fairness of the termination of parental rights process. View "In re Yasiel R." on Justia Law

After a jury trial, Defendant was convicted of capital felony, murder, and felony murder. The convictions arose from the killing of a single victim. The Appellate Court reversed in part and and remanded the case with direction to vacate Defendant’s convictions of murder and felony murder, concluding that those convictions violated constitutional protections against double jeopardy because they were cumulative of the controlling conviction of capital felony. The State appealed, asserting that vacatur was not the appropriate remedy for Defendant’s cumulative conviction of felony murder that violated his double jeopardy protections. The Supreme Court affirmed, holding that the vacatur remedy set forth in State v. Polanco should extend to scenarios like Defendant’s, thus making it appropriate to vacate his cumulative felony murder conviction. View "State v. Miranda" on Justia Law