Justia Connecticut Supreme Court Opinion Summaries

In Miller v. Alabama, the U.S. Supreme Court held that mandatory sentencing schemes that impose on juvenile offenders a term of life imprisonment without parole violate the Eighth Amendment. At issue in this case was whether a life sentence without parole may be imposed on a juvenile homicide offender in the exercise of the sentencing authority’s discretion. Defendant, who was seventeen years old at the time of the crimes leading to his convictions, was convicted of murder and other crimes. Defendant was sentenced to a total effective sentence of 100 years imprisonment, which was the functional equivalent to life without the possibility of parole. The Supreme Court reversed, holding (1) in considering whether to sentence a juvenile to a discretionary sentence of life imprisonment without the possibility of parole, the sentencer is required to take into account the factors that Miller deemed constitutionally significant before determining that such severe punishment is appropriate; and (2) in light of the uncertainty of Defendant’s sentence upon due consideration of the Miller factors, a new sentencing proceeding must be held that conforms with the dictates of Miller. View "State v. Riley" on Justia Law

After a jury trial, Defendant was convicted of one count of murder. On appeal, Defendant asserted that the trial court abused its discretion by (1) excusing a juror for injecting extraneous matters into deliberations and for refusing to deliberate; (2) excusing a second juror who was absent for one day without inquiring how long she would be unavailable; and (3) admitting into evidence testimony and a video recording relating to Defendant's refusal to cooperate with the police as they were taking a buccal swab from him. The Supreme Court affirmed, holding that the trial court did not abuse its discretion in (1) excusing the two jurors from the jury; (2) denying Defendant’s motions for a mistrial after the court excused the two jurors; and (3) admitting, as consciousness of guilt evidence, the testimony and video record of Defendant’s refusal to cooperate with the police. View "State v. Gonzalez" on Justia Law

Petitioner, an inmate at McDougall Correctional Institution, was found guilty of possession of contraband. After a hearing at which Petitioner was permitted to present witnesses and to testify on his own behalf, the Inmate Classification Administrator, ordered that Petitioner be placed in administrative segregation at Northern Correctional Institution, the state’s maximum security prison. Petitioner subsequently filed a habeas petition, which the habeas corpus denied. Petitioner appealed, arguing that the habeas court abused its discretion because it did not address his contention that his placement in administrative segregation violated his right to due process. The Appellate Court rejected Petitioner’s claims. The Supreme Court affirmed, holding (1) the Appellate Court incorrectly indicated that Connecticut prisoners can never establish a liberty interest in avoiding administrative segregation; (2) the Appellate Court incorrectly determined that the habeas court acted within its discretion in denying the petition for certification to appeal from the judgment of the habeas court because the habeas court’s reason for denying that petition was unsupportable; but (3) even if Petitioner had a liberty interest in avoiding his transfer to Northern, he received all of the process he was due prior to that transfer. View "Vandever v. Comm’r of Corr." on Justia Law

After a jury trial, Defendant was convicted of burglary in the first degree and kidnapping in the first degree. The Appellate Court vacated Defendant’s conviction and ordered a hearing to determine whether a competency evaluation was required, determining that the trial court had violated Defendant’s right to due process by failing to conduct a proper inquiry into Defendant’s competency. The Supreme Court affirmed, holding (1) the Appellate Court properly determined that the trial court’s independent inquiry into Defendant’s request for a competency evaluation was inadequate; (2) under the specific facts of this case, it was an abuse of the trial court’s discretion not to order a competency hearing; and (3) the remedy ordered by the Appellate Court was in line with United States Supreme Court precedent. Remanded. View "State v. Dort" on Justia Law

Defendant, who had an extensive weapons collection, was transporting a dirk knife, police baton and other weapons from his former residence in Connecticut to his new residence in Massachusetts when he was involved in a traffic accident. The State subsequently charged Defendant with six counts of having a weapon in a motor vehicle in violation of Conn. Gen. Stat. 29-38(a). A jury found Defendant guilty of two counts. The Supreme Court reversed, holding that the current statutory scheme, which categorically bars the transportation of a dirk knife and police baton by motor vehicle from a former residence to a new residence, impermissibly infringes on a person’s constitutional right under the second amendment to possess those weapons. View "State v. DeCiccio" on Justia Law

After a jury trial, Defendant was convicted of two counts of risk of injury to a child. The Appellate Court affirmed. The Supreme Court affirmed, holding (1) Defendant’s claim of error in the admission of out-of-court statements of one of the victims through the testimony of a police officer to provide context for Defendant’s admission to the conduct underlying the charges against him was not properly preserved; (2) even assuming that certain out-of-court statements of one of the victims that were admitted through the testimony of the state’s expert as examples of their age inappropriate knowledge were improperly admitted, any impropriety was harmless; and (3) Defendant was not deprived of a fair trial by any purported prosecutorial impropriety. View "State v. Paul B." on Justia Law

Plaintiff filed suit against Defendants, Plaintiff's employer and manager, alleging that she was discriminated against on the basis of her physical disability and/or her perceived disability, among other claims. The trial court granted summary judgment for Defendants on the disability discrimination claim to the extent that it alleged a cause of action based on a perceived physical disability, concluding that a cause of action based on a perceived disability is not a legally recognized action in Connecticut. The Appellate Court affirmed. The Supreme Court reversed in part, holding that the Connecticut Fair Employment Practices Act not only protects individuals who have a physical disability, but also individuals who are regarded by their employers as having a physical disability. View "Desrosiers v. Diageo N. Am., Inc." on Justia Law

After a jury trial, Defendant was convicted of one count of intentional manslaughter in the first degree with a firearm. Defendant appealed, arguing, among other things, that his conviction violated his constitutionally protected right against double jeopardy because a reasonable possibility existed that he was acquitted of the offense at an earlier trial. The Supreme Court affirmed, holding (1) Defendant’s conviction did not violate right against double jeopardy; and (2) any error committed by the trial court in construing the term “crime of violence” and in instructing the jury on the elements of the various offenses that fall within the definition of “crime of violence” was harmless beyond a reasonable doubt. View "State v. Terwilliger" on Justia Law

After a jury trial, Petitioner was found guilty of murder, conspiracy to commit murder, and larceny in the first degree. The Appellate Court affirmed the judgment. Nearly nine years later, Petitioner filed an amended petition for writ of habeas corpus alleging that he received ineffective assistance of counsel at trial because his counsel failed to call two witnesses whose testimony would have contradicted that of an important state’s witness regarding Petitioner’s motive to commit the offenses for which he was found guilty. The habeas court denied the petition and, further, denied Petitioner’s request for certification to appeal. The Appellate Court dismissed Petitioner’s appeal. The Supreme Court affirmed, holding that assuming, without deciding, that the habeas court’s denial of certification was an abuse of discretion, Petitioner failed to demonstrate that he was entitled to a new trial. View "Sanchez v. Comm’r of Corr." on Justia Law

After a jury trial, Defendant was found guilty of assault of public safety personnel. Defendant appealed, arguing that his rights to equal protection were violated, along with the same rights of a venireperson, C.D., who was excluded from the jury on the basis of C.D.’s answer to a question about race. Defendant further argued that the Supreme Court should exercise its supervisory authority to disallow peremptory challenges based on answers to the question about race in the juror questionnaire. The Supreme Court affirmed the judgment of the trial court, holding (1) the constitutional rights of Defendant and C.D. were not violated, as the prosecutor articulated a race neutral, nonpretextual explanation for his peremptory challenge; and (2) the Court declines to invoke its supervisory authority in the present case. View "State v. Edwards" on Justia Law