Justia Connecticut Supreme Court Opinion Summaries

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

After a jury trial, Defendant was convicted of sexual assault in the first degree, sexual assault in the fourth degree, and risk of injury to a child. Defendant appealed, arguing that the prosecutor improperly commented on his right not to testify during her closing argument at trial. The Appellate Court affirmed. The Supreme Court affirmed, holding that the prosecutor did not engage in any impropriety and that her comments were within the constitutional limits prescribed by the Fifth Amendment. View "State v. Ruffin" on Justia Law

After a jury trial, Defendant was convicted of sexual assault in the first degree, sexual assault in the fourth degree, and risk of injury to a child. The Supreme Court affirmed, holding (1) even though Defendant was only fourteen and fifteen years old when he committed the crimes, the trial court did not err in imposing the mandatory minimum sentences for the first degree sexual assault conviction and the risk of injury conviction, as the mandatory minimum requirements left the trial court with broad discretion to fashion an appropriate sentence that accounted for Defendant’s youth and immaturity when he committed the crimes; (2) the state’s expert witness did not improperly vouch for the credibility of the victim; and (3) Defendant’s argument that the trial court improperly admitted evidence of sexual misconduct committed by Defendant when he was thirteen years old on propensity grounds was unpreserved for appeal. View "State v. Taylor G." on Justia Law