Justia Connecticut Supreme Court Opinion Summaries

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

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

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

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

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

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

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

After a jury trial, Petitioner was convicted of sexual assault in the first degree and risk of injury to a child. The Appellate Court affirmed the convictions on direct appeal. Petitioner later sought habeas relief, claiming that his appellate counsel provided ineffective assistance by failing to investigate Petitioner’s claims that he had a history of sexually transmitted diseases and to introduce evidence concerning whether the victim had contracted any such diseases. The habeas court rejected Petitioner’s claim. The Appellate Court affirmed. The Supreme Court affirmed, holding that Petitioner failed to demonstrate that he was prejudiced by any deficiency in counsel’s performance. View "Anderson v. Comm’r of Corr." on Justia Law

After a jury trial, Defendant was found guilty of two drug-related offenses following a police investigation that culminated in the seizure of heroin from defendant’s home pursuant to a search warrant. Defendant appealed, arguing, among other things, that the trial court erred in denying her motion to suppress certain statements because the statements had been obtained when a police officer interrogated her during the execution of the search warrant without first advising her in accordance with Miranda v. Arizona. The appellate court affirmed the convictions, determining that, at the time of the police questioning, Defendant was not in custody for purposes of Miranda, and therefore, Miranda warnings were not required. The Supreme Court reversed, holding (1) Defendant was in custody when she was questioned by the police officer, and, as a result, the police were required to advise her of her rights under Miranda; and (2) the Miranda violation was not harmless beyond a reasonable doubt.View "State v. Mangual" on Justia Law

After a jury trial, Defendant was convicted of one count of murder and one count of felony murder. The Supreme Court affirmed, holding that the trial court (1) properly admitted evidence of uncharged sexual misconduct; (2) properly rejected Defendant’s claim under Brady v. Maryland that he was denied a fair trial because the state failed to disclose an alleged agreement or understanding with a key witness that she would be given a benefit if she testified for the state, as there was no agreement or understanding between the witness and the state prior to her testimony; and (3) properly permitted the prosecutor to exercise a peremptory challenge with respect to an African-American venireperson. View "State v. Smith" on Justia Law