Justia Connecticut Supreme Court Opinion Summaries
Articles Posted in Constitutional Law
State v. Terwilliger
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
Sanchez v. Comm’r of Corr.
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
State v. Edwards
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
State v. Kendrick
After a jury trial, Defendant was convicted of criminal possession of a firearm. Defendant appealed, arguing that the trial court erred in denying his motion to suppress evidence obtained by law enforcement officers as a result of their warrantless entry into a bedroom where he was sleeping. The Appellate Court reversed, concluding that it was unreasonable for the police to assume that Defendant was present in the bedroom and posed an imminent threat of harm to the apartment’s occupants. The Supreme Court reversed, holding that, under the totality of the circumstances, the police officers reasonably believed that the warrantless entry into the bedroom was necessary to protect their own safety and the safety of others on the premises, and therefore, the entry did not violate Defendant’s Fourth Amendment rights. View "State v. Kendrick" on Justia Law
State v. Artis
After a jury trial, Defendant was found guilty of accessory to assault in the first degree by means of a dangerous weapon. Defendant appealed, arguing that the trial court abused its discretion in denying his motion to suppress the victim’s out-of-court and in-court identifications of him as one of the victim’s assailants. The Appellate Court reversed, concluding that the admission of Defendant’s identifications following an unnecessarily suggestive procedure by the police violated Defendant’s constitutional rights, and the error was not harmless beyond a reasonable doubt. The Supreme Court reversed, holding (1) contrary to the Court’s holding in State v. Gordon, the improper admission of suggestive and unreliable identification is subject to harmless error analysis; and (2) assuming, without deciding, that the trial court erred in denying Defendant’s motion to suppress the victim’s identification testimony, the error was harmless. View "State v. Artis" on Justia Law
State v. Ciullo
After a jury trial, Defendant was convicted of two counts of unlawful restraint in the first degree. Defendant appealed, arguing that the prosecutor engaged in certain improprieties that deprived him of his due process right to a fair trial. The Appellate Court affirmed, holding that reversal of Defendant’s convictions was unwarranted. The Supreme Court affirmed, holding that, considering the alleged prosecutorial improprieties within the context of the entire trial, the instances of alleged prosecutorial impropriety identified by Defendant did not affect the fairness of the trial or prejudice Defendant under the standard set forth in State v. Williams. View "State v. Ciullo" on Justia Law
State v. Pierre
Upon responding to a 911 call from a tenant of a rooming house reporting a disturbance involving a gun, police officers entered an unlocked attic space in the house and retrieved marijuana and a gun. After a jury trial, Defendant, who resided in a room on the third floor of the house, was convicted of attempt to commit criminal possession of a firearm, criminal possession of a pistol, and possession of marijuana with intent to distribute. Defendant appealed the denial of his motion to suppress the evidence seized by the police as products of an unlawful search, claiming he had a reasonable expectation of privacy in the attic. The appellate court affirmed, holding that, because of Defendant’s lack of control over the access of others to the attic, Defendant did not have an expectation of privacy in that space that society would recognize as reasonable. The Supreme Court affirmed, holding that appellate court properly resolved the issue by virtue of its well-reasoned decision.View "State v. Pierre" on Justia Law
State v. Benedict
After a jury trial, Defendant was convicted of one count of sexual assault in the fourth degree. During trial, in seeking to imply that the complainant had a motive to testify favorably for the State, Defendant sought to question the complainant on recross-examination about the conditions of her participation in a pretrial diversionary program on a felony charge pending against her in an unrelated case. The trial court concluded that the prejudicial effect of the proffered evidence was greater than its probative value. The Appellate Court reversed the conviction, concluding that the trial court violated Defendant’s right to confrontation by precluding Defendant from eliciting such evidence. The Supreme Court reversed, holding that Defendant failed to establish a sufficient nexus between the testimony he sought to obtain and the complainant’s motive to testify favorably for the State to implicate his right to confrontation. View "State v. Benedict" on Justia Law
Edgerton v. Town of Clinton
Walter Hopkins was severely injured as a result of the second of two vehicle collisions. Hopkins was the passenger in an Infiniti, which struck the side of a vehicle driven by Matthew Vincent, a volunteer firefighter. Vincent pursued the Infiniti at high speeds in his vehicle, at which time he relayed information via cell phone regarding the Infiniti and its location to Ellen Vece, a 911 dispatcher employed by the Town of Clinton. The Infiniti eventually crashed into a tree. Hopkins required permanent care as a result of his injuries. An action was filed on Hopkins' behalf against the Town, among others. The jury found in favor of the plaintiff, finding (1) the Town was liable under the identifiable person-imminent harm exception to governmental immunity; and (2) Vece’s failure to act was a proximate cause of Hopkins’ injuries. The Supreme Court reversed, holding that the identifiable person-imminent harm exception to the doctrine of governmental immunity did not apply in this case because the circumstances would not have made it apparent to Vece that her failure to instruct Vincent to stop following the Infiniti likely would have subjected Hopkins to imminent harm.View "Edgerton v. Town of Clinton" on Justia Law
Posted in:
Constitutional Law, Injury Law
State v. Krijger
Defendant’s conviction for threatening in the second degree and breach of the peace in the second degree arose out of statements he made to an attorney that represented the Town of Waterford in a zoning dispute with Defendant. On appeal, Defendant argued that his statements were protected by the First Amendment to the Federal Constitution because they were not real or true threats. The Appellate Court affirmed. The Supreme Court reversed, holding that Defendant was entitled to a judgment of acquittal on both charges, as Defendant’s statements did not rise to the level of a true threat and were therefore entitled to the protection of the First Amendment despite their inflammatory nature. View "State v. Krijger" on Justia Law