Justia Connecticut Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of risk of injury to a child and sexual assault in the fourth degree. The Supreme Court reversed the trial court's judgment, holding (1) the prosecutor made improper statements during closing arguments and in connection with defense counsel's cross-examination of key state's witnesses, and the prosecutorial impropriety deprived Defendant of his due process right to a fair trial; and (2) the trial court improperly admitted into evidence a video recording and transcript of a forensic interview of the victim under the tender years exception to the hearsay rule without first conducting a hearing. Remanded for a new trial.View "State v. Maguire" on Justia Law

After a jury trial, Defendant was convicted of sexual assault in the first degree and risk of injury to a child. The Supreme Court reversed the judgment of the trial court and remanded for a new trial, holding (1) the trial court abused its discretion by improperly precluding Defendant from introducing, on relevancy grounds, evidence of prior sexual conduct that was admissible under the rape shield statute, in violation of Defendant’s federal and state constitutional rights to confrontation; and (2) the trial court’s preclusion of the evidence was not harmless beyond a reasonable doubt. View "State v. Shaw" on Justia Law

After a jury trial, Defendant was convicted of several crimes. On appeal, Defendant argued that, during sentencing, the trial court deprived him of his due process rights by improperly considering that Defendant decided to proceed to trial rather than accept a plea bargain. The Appellate Court declined to review Defendant’s sentencing claim on the grounds that it was unpreserved and that Defendant had not properly made an “affirmative request” for review in his main brief under State v. Golding. The Supreme Court reversed in part, holding (1) the requirement that a defendant must “affirmatively request” Golding review in his main brief in order to receive appellate review of unpreserved constitutional claims is overruled, and therefore, the Appellate Court improperly declined to review Defendant’s constitutional claims on that ground; (2) Defendant failed to establish that the trial court penalized him for exercising his right to a jury trial; but (3) the use of the Court’s supervisory authority was warranted to prevent adverse effects on the public’s perception of the inherent fairness of the criminal justice system that may arise when a trial judge could appear to have considered a defendant’s decision to exercise his right to a trial during sentencing. Remanded for a new sentencing hearing. View "State v. Elson" on Justia Law

After a jury trial, Defendant was convicted of murder and other crimes. The Supreme Court (1) reversed the judgment of the trial court as to Defendant’s convictions for the crimes of kidnapping in the second degree and burglary in the first degree, holding that certain evidence relating to the potential impeachment of a key prosecution witness should have been admitted at trial, and that the failure to admit the evidence was not harmless beyond a reasonable doubt as to those counts; and (2) affirmed the trial court in all other respects, holding that the court did not err in its instructions to the jury and that the prosecutor did not engage in misconduct. View "State v. Baltas" on Justia Law

Petitioner was convicted of second degree murder and death of a child by a parent, guardian, or custodian. Petitioner filed a petition for a writ of habeas corpus, claiming that he had been punished twice for the same offense and, thus, his convictions violated the proscription against double jeopardy. The Supreme Court affirmed the judgment of the trial court, holding that the two offenses of which Petitioner was charged and convicted were separate and distinct pursuant to the test set forth under Blockburger v. United States because (1) intent to kill is an element of second degree murder but is not an element of the offense of death of a child by a parent, guardian, or custodian; and (2) the offense of death of a child by a parent, guardian, or custodian by child abuse contains elements of proof not required to establish second degree murder.View "State v. Freeman" on Justia Law

After a jury trial, Defendant was found guilty of breach of the peace in the second degree and harassment in the second degree for allegedly threatening a coworker during a telephone call. The appellate court reversed, concluding (1) the trial court improperly failed to instruct the jury that it could find Defendant guilty of the breach of the peace charge only if it found Defendant's offending speech was a real or true threat not entitled to protection under the First Amendment; and (2) where the telephone harassment statute bars conduct only, the evidence was insufficient to convict Defendant of the harassment charge because the the case was predicated entirely on Defendant's speech. The Supreme Court affirmed, holding (1) the jury instructions on the breach of the peace charge were inadequate to ensure Defendant was not convicted on the basis of constitutionally protected speech; and (2) the telephone harassment statute applied to speech as well as conduct, but because Defendant did not have fair notice that she could be subjected to punishment for the verbal content of the telephone call, the harassment charge must be dismissed. View "State v. Moulton" on Justia Law

Complainants, an attorney and the Office of the Chief Public Defender, submitted a request for a declaratory ruling to the Connecticut Medical Examining Board asking whether physician participation in the execution of condemned inmates using lethal injection was permitted. Complainants then sent a letter regarding their request for a declaratory ruling. The Board convened an executive session to obtain legal advice about issues raised in the letter. Complainants then filed a complaint with the Commission, alleging that Plaintiffs, the Board and its chairperson, violated the Freedom of Information Act by convening in executive session during the meeting for "purposes not permitted" under the Act. The Commission determined the executive session was impermissible under the Act. The trial court upheld the Commission's decision. The Supreme Court affirmed, holding that the letter did not constitute notice of a pending claim as defined by Conn. Gen. Stat. 1-200, and therefore, the Board was not permitted to convene in executive session under the Act. View "Chairperson, Conn. Med. Examining Bd. v. Freedom of Info. Comm'n" on Justia Law

After a jury trial, Defendant was convicted of murder. Defendant appealed, contending, among other things, that statements he made to the court during a pretrial hearing and at sentencing indicating dissatisfaction with the performance of his appointed counsel resulted in a clear and unequivocal request invoking the right to self-representation under the Sixth Amendment. The appellate court affirmed Defendant's conviction, concluding that Defendant's statements to the court did not develop into a clear and unequivocal request for self-representation. The Supreme Court affirmed, holding that the trial court did not violate Defendant's right to self-representation during the criminal proceedings.View "State v. Pires" on Justia Law

Petitioner entered conditional pleas of nolo contendere to several felony offenses. The appellate court affirmed. Petitioner filed an amended petition for a writ of habeas corpus, alleging that his counsel rendered ineffective assistance. Petitioner's appellate counsel, who also served as his trial counsel, failed to file a petition for certification with the Supreme Court challenging the propriety of the appellate court's judgment. The habeas court granted the petition in part and ordered that Petitioner's right to file a petition for certification to appeal to the Supreme Court be restored. The appellate court reversed, concluding that Petitioner failed to introduce evidence that he was prejudiced by counsel's deficiency. The Supreme Court reversed, holding that Petitioner's habeas action was not justiciable because it was not ripe for adjudication. Remanded with direction to dismiss the habeas petition.View "Janulawicz v. Comm'r of Corr." on Justia Law

Plaintiff, who worked for Defendant as a plumber, brought this action seeking payment of overtime wages for, among other things, his daily commute between his home and the job sites. The trial court concluded that Defendant was not entitled to overtime compensation for his travel time between home and work because the Fair Labor Standards Act (FLSA) preempted the relevant Connecticut laws and regulations governing overtime and travel time. The Supreme Court affirmed, holding that because section 31-60-10 of the Regulations of Connecticut State Agencies, as applied to the facts of this case, confers lesser benefits on employees than those afforded under the FLSA, federal preemption applies, and therefore, Plaintiff was not entitled to compensation for his commuting time. View "Sarrazin v. Coastal, Inc." on Justia Law