Justia Connecticut Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of two counts of risk of injury to a child. The appellate court reversed the conviction and remanded the case for a new trial. The State appealed, claiming that the appellate court improperly concluded that (1) the trial court abused its discretion in admitting into evidence four statements by an expert witness, each to the effect that the complainant exhibited behaviors consistent with those of sexual abuse victims; and (2) reversal was required because these improper evidentiary rulings were not harmless error. The Supreme Court affirmed, holding that the four statements were improperly admitted into evidence, and the Court did not have a fair assurance that those improprieties did not substantially sway the jury's verdict. View "State v. Favoccia" on Justia Law

After a jury trial, Defendant was convicted of murder and conspiracy to commit murder. The Supreme Court affirmed, holding (1) there was sufficient evidence to sustain Defendant's conviction of conspiracy to commit murder; (2) the prosecutor did not engage in impropriety by eliciting from a key state witness a statement that she would never lie, and the prosecutor did not argue outside of the evidence in his rebuttal argument, and therefore, the prosecutor did not engage in improper conduct; and (4) the record was ineffective was inadequate for review of both of Defendant's claims of ineffective assistance of counsel, and accordingly, the ineffective assistance claims should be resolved after an evidentiary hearing in the trial court. View "State v. Taft" on Justia Law

After a jury trial, Defendant was convicted of sexual assault in the first degree and kidnapping in the first degree in violation of Conn. Gen. Stat. 53a-92(a)(2)(A). After a trial to the court, Defendant was convicted of violation of probation. Defendant appealed, raising two claims of error. The Supreme Court reversed in part the judgment of the trial court, holding (1) the court erred in omitting limiting language in instructing the jury that the phrase "without consent," as defined by Conn. Gen. Stat. 53a-91(a)(1) includes "any means whatsoever, including acquiescence of the victim," for purposes of the restraint element of section 53a-92(a)(2); and (2) it was reasonably possible that the trial court's improper instruction had the effect of misleading the jury, and a new trial was, therefore, required on the kidnapping charge. View "State v. Devalda" on Justia Law

After a jury trial, Defendant was convicted of, inter alia, sexual assault in the first degree. Defendant appealed, claiming that the trial court improperly denied his motion to dismiss because the statute of limitations applicable to the offense had expired and had not been tolled because he left the state. Defendant's principal assertion was that he did not flee the state because he was returning to his home in Massachusetts after the commission of the crime. The Supreme Court affirmed, holding (1) it was undisputed that Defendant returned to Massachusetts after the commission of a crime and continued to reside there until his arrest more than twenty years later, and accordingly, the trial court properly denied Defendant's motion to dismiss because it properly concluded that the state had shown probable cause that the statute of limitations had been tolled; (2) the trial court properly denied Defendant's motion for a judgment of acquittal because the state proved there was sufficient evidence that Defendant fled the state; and (3) the trial court's instructions on the statute of limitations defense were not misleading. View "State v. Ward" on Justia Law

A jury found Defendant guilty of sexual assault in the first degree and kidnapping in the first degree. The trial court granted Defendant's motion for judgment of acquittal on the kidnapping charge on the ground that the State had failed to prove beyond a reasonable doubt that Defendant intended to prevent the liberation of the victim for a longer period of time or to a greater degree than that which was necessary to commit the sexual assault as required by State v. Salamon. The Supreme Court reversed the judgment of the trial court as to the kidnapping charge, holding (1) the trial court improperly improperly granted Defendant's motion for judgment of acquittal and rendered judgment of not guilty on the kidnapping charge, as the jury reasonably could have concluded that Defendant's restraint of the victim was not merely incidental to the sexual assault; (2) the judgment may not be affirmed on the alternate ground that the kidnapping statute, as applied to Defendant's conduct, was unconstitutionally vague; and (3) the trial court's instruction on the kidnapping charge was not misleading. Remanded. View "State v. Ward" on Justia Law

After a jury trial, Petitioner was convicted of capital felony, two counts of murder, and conspiracy to commit murder, and he was sentenced to an effective term of life imprisonment without the possibility of release. The Supreme Court upheld all four convictions on appeal. Petitioner subsequently filed an amended petition for a writ of habeas corpus, alleging that he had been denied the effective assistance of counsel based on his claim that counsel failed to complete an adequate pretrial investigation. The habeas court granted petitioner's petition, and the appellate court affirmed. The Supreme Court affirmed, holding that Petitioner established by a preponderance of he evidence both that defense counsel had rendered ineffective assistance and that the alleged ineffective assistance was prejudicial to Petitioner. View "Gaines v. Comm'r of Corr." on Justia Law

The named plaintiff, on her own behalf and on behalf of her minor son, brought this action against defendant city (Defendant), claiming that her son incurred injuries when a fellow student pushed him into a broken locker. Defendant filed its its answer and a special defense claiming municipal immunity. Plaintiffs denied the special defense but failed to plead that any exception to the defendant's immunity applied to them. The court instructed the jury on principles of negligence but made no reference to the special defense. The jury rendered a verdict for Plaintiffs. The trial court then granted Defendant's motion for a directed verdict and the motion to set aside the verdict on the ground of governmental immunity and rendered judgment for Defendant. The appellate court affirmed on the alternative ground that Plaintiffs failed to plead the identifiable victim, imminent harm exception to municipal immunity in their reply. The Supreme Court reversed, holding that because Plaintiffs did not have adequate notice of this alternative basis or sufficient opportunity to address it, the appellate court improperly decided the case on the basis of Plaintiffs' failure to plead the imminent harm exception to discretionary act immunity. View "Haynes v. City of Middletown" on Justia Law

A jury found Defendant guilty of reckless driving. The trial court rendered judgment in accordance with the jury verdict. The appellate court reversed the judgment of the trial court with respect to the reckless driving conviction on the ground that the evidence was insufficient to establish that the street on which Defendant was driving was a public highway, as required under Conn. Gen. Stat. 14-222(a). The Supreme Court (1) reversed in part the judgment of the appellate court, holding that the evidence was sufficient to permit a finding that Defendant was operating his motor vehicle on a public highway; and (2) affirmed in all other respects. View "State v. Taylor" on Justia Law

Defendant was convicted, after a jury trial, of sexual assault in the first degree and risk of injury to a child. The appellate court affirmed the judgment of conviction. Defendant appealed, claiming that he was denied a fair trial because the trial court's preliminary instruction to the jury regarding posttrial sentencing procedures and the trial court's final instruction to the jury regarding the minor victim's credibility were improper. The Supreme Court affirmed, holding that the appellate court (1) properly determined that mentioning sentencing proceedings in the preliminary instructions did not affect the overall fairness and integrity of the proceeding as a whole; and (2) properly determined that the trial court's jury instructions regarding the victim's credibility, read as a whole, did not clearly violate Defendant's constitutional rights or clearly deprive him of a fair trial. View "State v. Makee R." on Justia Law

A jury found Defendant guilty of capital felony, two counts of murder, and assault in the first degree. The Supreme Court affirmed the judgments of the trial court, holding (1) State v. Kemp and State v. McClendon, which state that expert testimony on the issue of reliability of eyewitness identification is disfavored, are expressly overruled; (2) accordingly, testimony by a qualified expert on the fallibility of eyewitness identification is admissible when that testimony would aid the jury in evaluating the state's identification evidence; (3) therefore, the trial court improperly precluded the defense from presenting certain expert testimony on the issue of eyewitness identification, but the impropriety was harmless; and (4) the trial court properly denied Defendant's motions for a mistrial and for a new trial, which stemmed from the state's delayed disclosure of certain allegedly exculpatory evidence, as Defendant was not so prejudiced by the late disclosure that he did not receive a fair trial. View "State v. Guilbert" on Justia Law