Justia Connecticut Supreme Court Opinion Summaries

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

Petitioner pleaded nolo contendere to a charge of assault in the first degree. Petitioner filed an amended habeas petition alleging that his trial counsel had failed to provide sufficient information to enable him to make an informed decision about whether to plead nolo contendere or to proceed to trial. The habeas court denied the petition, concluding that Petitioner was not prejudiced by his counsel’s alleged errors. The Appellate Court reversed, concluding that the prejudice standard enunciated in Copas v. Commissioner of Correction that the habeas court applied in this case was inconsistent with federal law concerning the prejudice prong. The Commissioner of Correction appealed, claiming that the Appellate Court improperly determined that the habeas court applied an incorrect legal standard. The Supreme Court dismissed the appeal for lack of subject matter jurisdiction, as the Commissioner was not aggrieved by the judgment of the Appellate Court and Copas has already been overruled sub silencio in subsequent decisions by the Court. View "Carraway v. Comm’r of Corr." on Justia Law

After a jury trial, Defendant was convicted of murder. On appeal, Defendant argued, among other things, that he was entitled to a new trial because the trial court improperly forced him to choose between his constitutional right to counsel and his constitutional right to testify on his own behalf after defense counsel stated that he would be self-represented if he testified against their advice. The Appellate Division affirmed, concluding that Defendant waived his right to counsel when he elected to testify at trial. The Supreme Court reversed, holding (1) Defendant was not represented by counsel during his testimony; and (2) Defendant was entitled to a new trial because he did not voluntarily relinquish his right to counsel. Remanded for a new trial. View "State v. Francis" on Justia Law

After a jury trial, Defendant, the Hartford Roman Catholic Diocesan Corporation, was found guilty of negligently and recklessly assigning Father Ivan Ferguson to serve as the director of Saint Marty’s Elementary School, where he sexually abused Plaintiff from 1981 through 1983. The Supreme Court affirmed, holding (1) there was sufficient evidence to support the jury’s verdict; (2) the trial court did not commit prejudicial error in its evidentiary rulings; (3) the trial court properly granted Plaintiff’s motion to strike Defendant’s laches defense; and (4) the retroactive application of certain amendments to the applicable statute of limitations to revive Plaintiff’s otherwise time barred claims did not violate Defendant’s substantive due process rights under the Connecticut Constitution. View "Doe v. Hartford Roman Catholic Diocesan Corp." on Justia Law

Petitioner entered a plea of nolo contendere to felony murder and related crimes. Petitioner was sixteen years old when he committed the crimes. The trial court sentenced Petitioner to a total effective prison term of fifty years with no possibility of parole. After Petitioner’s conviction and sentence became final, the U.S. Supreme Court decided Miller v. Alabama. Petitioner filed a petition for a writ of habeas corpus arguing that the statutory authority under which his fifty year prison term with no possibility of parole was imposed violated the Eighth Amendment as applied to him. The habeas court granted summary judgment for the State, concluding that Miller did not apply to Petitioner’s sentence. The Supreme Court reversed, holding (1) Miller applies retroactively under Connecticut law to cases arising on collateral review; and (2) Miller applies to the imposition of a fifty year sentence on a juvenile offender. Remanded. View "Casiano v. Comm’r of Corr." on Justia Law

After a jury trial, Defendant was convicted of murder and tampering with physical evidence. Defendant appealed, arguing that the trial court erred in failing to suppress (1) certain oral statements made to police officers after his apprehension on the ground that the statements were the result of a custodial interrogation without his having been read his Miranda warnings, and (2) a statement he made after being given his Miranda warnings on the ground that it was the product of coercion. The Supreme Court affirmed, holding that the trial court properly denied Defendant’s motion to suppress, as (1) Defendant was not subjected to custodial interrogation before receiving the Miranda warnings; and (2) Defendant’s confession was made voluntarily. View "State v. Ramos" on Justia Law

After a jury trial, Petitioner was found guilty of murder and carrying a pistol without a permit. The Appellate Court affirmed on direct appeal. Thereafter, Petitioner collaterally attacked his conviction by filing a petition for a writ of habeas corpus, claiming that his trial attorney had rendered ineffective assistance of counsel. The habeas court denied the habeas petition. On appeal, Petitioner raised for the first time a new theory as to why his attorney had rendered ineffective assistance. The Appellate Court declined to review Petitioner’s claim on the grounds that that review under State v. Golding is not available for unpreserved claims of error raised for the first time in a habeas appeal. The Supreme Court affirmed, holding that Golding review was unavailable for Petitioner’s ineffective assistance claim because that claim did not arise out of the actions or omissions of the habeas court itself. View "Moye v. Comm’r of Corr." on Justia Law

After a jury trial, Petitioner was convicted of capital felony and arson murder, among other offenses. Petitioner sought a writ of habeas corpus alleging that his due process rights were violated because the State had failed to disclose a note written by a police detective containing details concerning the length of time that the fire burned inside the victim’s apartment prior to being discovered. First habeas counsel failed to pursue the claim, and consequently, the first habeas court rejected that claim as abandoned. Petitioner subsequently filed this habeas petition, alleging that the State withheld the evidence in violation of Brady v. Maryland and that his first habeas counsel had rendered ineffective assistance by failing to pursue and prove that claim. The second habeas court dismissed the claim. The Appellate Court remanded. The third habeas court rejected the petition. The Appellate Court reversed in part and remanded with direction to grant the petition for a writ of habeas corpus and for a new trial. The Supreme Court affirmed, holding that Petitioner was deprived of a fair trial because his rights under Brady were violated and that Petitioner’s first habeas counsel provided ineffective assistance by failing to establish that violation. View "Lapointe v. Comm’r of Corr." on Justia Law

Plaintiff brought this action pursuant to the Connecticut Fair Employment Practices Act alleging that Defendant, her employer, had engaged in sexual harassment and disability discrimination and had unlawfully terminated her on the basis of her national origin, religion, and race. The trial court granted summary judgment on all counts in favor of Defendant. The Appellate Court affirmed. The Supreme Court reversed with respect to Plaintiff’s claim of sexual harassment in the workplace and affirmed in all other respects, holding that Plaintiff established a genuine issue of material fact as to whether she was subjected to a hostile work environment on the basis of her sex. Remanded. View "Feliciano v. Autozone, Inc." on Justia Law