Justia Connecticut Supreme Court Opinion Summaries

Under Conn. Gen. Stat. 54-lj(c), when a noncitizen defendant has not been properly advised about the deportation consequences of his guilty plea, the court is mandated to permit withdrawal of the guilty plea of the defendant files a motion not later than three years after the acceptance of the plea. At issue in this case was whether the trial court has jurisdiction under section 54-lj to vacate the judgment and permit withdrawal of the plea, as a matter of discretion, if the motion to vacate is filed more than three years after the court's acceptance of the plea. Defendant in this case appealed from the trial court's judgment denying his motion to vacate his judgment of conviction and to withdraw his plea. The trial court concluded it had jurisdiction to consider Defendant's motion but held that the present case was not one in which the court should exercise its discretion to vacate the judgment. The Supreme Court reversed, holding that the trial court should have dismissed, rather than denied, the motion to vacate because the court lacked jurisdiction to consider the merits of Defendant's motion because the motion was filed outside the permit under section 54-lj(c). Remanded. View "State v. Ramos" on Justia Law

Defendant was convicted of two counts of failing to comply with the sex offender registry requirements of Conn. Gen. Stat. 54-251 stemming from his failure to notify the sex offender registry unit of his change of residence in accordance with the terms of that statute. In count one, the state charged that on December 31, 2007, Defendant failed to notify the appropriate authority of his change of residence. In count two, the state charged that on January 22, 2008, in another town, Defendant failed to notify the commissioner of public safety of his change of residence. Defendant appealed, claiming that the trial court improperly determined that there was sufficient evidence to prove he violated the statute. The Supreme Court agreed and reversed, holding that there was insufficient evidence to convict Defendant on either count of the information. View "State v. Drupals" on Justia Law

After a jury trial Defendant was convicted of felony murder, conspiracy to commit robbery in the third degree, and robbery in the first degree. The appellate court affirmed. At issue in this certified appeal was whether the trial court properly instructed the jury on the statutory exception to the duress defense set forth in Conn. Gen. Stat. 53a-14, when the State claimed that Defendant had intentionally or recklessly placed herself in a situation in which it was probable that she would be subjected to duress by voluntarily resuming her relationship with an abusive boyfriend. The Supreme Court affirmed the judgment of the appellate court on the ground that, even if the trial court's instruction on the statutory exception to the duress defense was improper, any impropriety was harmless. View "State v. Helmedach" on Justia Law

Defendant Gary Weddle and the intervening Defendant, the conservation commission of the town of Fairfield, appealed from the trial court's decision granting the writ of quo warranto filed by Plaintiffs, certain concerned taxpayers of the town of Fairfield, and ordering Weddle's removal from the office of wetlands compliance officer. On appeal, the Supreme Court reviewed the procedural and substantive requirements for maintaining a quo warranto action. The Court affirmed the decision of the trial court, holding (1) plaintiffs demonstrated sufficient interest to establish standing to pursue the quo warranto action; and (2) the trial court properly granted Plaintiffs' writ of quo warranto on the basis that Weddle's appointment to the wetland compliance officer position violated the town charter by usurping the office of the conservation director. View "Bateson v. Weddle" on Justia Law

Defendant was convicted of two counts of larceny in the first degree by false pretenses. The parties agreed that the appellate court properly concluded that the trial court improperly failed to instruct the jury that it could aggregate the value of the property stolen in individual thefts only if it first concluded that the thefts were part of one scheme or course of conduct. Defendant, however, argued that the appellate court improperly concluded that the improper instruction was harmless beyond a reasonable doubt. The Supreme Court affirmed the judgment of the appellate court, holding that the error was harmless because Defendant did not contest the issue and the evidence so overwhelmingly supported the determination that the multiple thefts were part of a single scheme that no reasonable jury could have concluded otherwise. View "State v. Thompson" on Justia Law

Plaintiff was summarily convicted of criminal contempt of court and sentenced to 120 days incarceration. Plaintiff petitioned for a writ of error, claiming that, because the trial court did not inform him of the charge against him or afford him an opportunity to present exculpatory or mitigating evidence, his conviction and sentence violated his due process rights. The Supreme Court dismissed the writ of error, holding (1) Plaintiff's claim was subject to the Court's review; (2) Plaintiff's conviction was proper, as the trial court substantially complied with Practice Book 1-16; and (3) to the extent that the state and federal constitutions embrace a requirement that a defendant in a summary contempt proceeding be afforded notice and an opportunity to allocute, the trial court substantially complied with that requirement. View "Hardy v. Superior Court" on Justia Law

Defendant was convicted following a jury trial of one count of risk of injury to a child and two counts of sexual assault in the first degree. Defendant appealed, claiming that the trial court denied his constitutional rights to present a defense and to due process by improperly precluding him from eliciting testimony from a pediatrician who had examined the victim regarding a statement that the victim had made to her. The Supreme Court affirmed, holding that Defendant abandoned his claim, as (1) the record was unclear weather the court in fact precluded Defendant from eliciting testimony regarding this statement, and (2) Defendant neither sought a clarification of the court's ruling nor sought to elicit testimony from the pediatrician regarding the statement. View "State v. Ricardo R." on Justia Law

Defendant Miguel C. was convicted, after a jury trial, of three counts of sexual assault in the first degree and three counts of risk of injury to a child. Defendant appealed, claiming that he was entitled to a new trial because the complainant improperly testified about an alleged confession by Defendant to his wife. The Supreme Court reversed the judgment of conviction and ordered a new trial, holding (1) the contested portion of the complainant's testimony was improperly admitted, as its probative value was outweighed by the prejudicial effect; and (2) the verdict was substantially affected by that testimony, and therefore, the error was harmful. View "State v. Miguel C." on Justia Law

Defendant was convicted of assault of public safety personnel. The appellate court reversed the conviction on the ground that the trial court had compelled Defendant to wear identifiable prison clothing at his jury trial in contravention of his constitutional right to a fair trial. The Supreme Court affirmed the judgment of the appellate court on the alternative ground that reversing Defendant's conviction was warranted in the exercise of the Court's inherent supervisory authority over the administration of justice, holding (1) in the absence of a defendant's voluntary decision to stand trial before a jury in prison clothing, a court must ensure that the defendant has civilian clothing to wear at trial, and its failure to comply with this requirement will result in reversal of the defendant's conviction; and (2) the trial court in this case erred in compelling Defendant to stand trial in identifiable prison clothing. View "State v. Rose" on Justia Law

Defendant Anthony Thompson was convicted of one count of murder and two counts of assault in the first degree. The Supreme Court affirmed, holding (1) the trial court applied the proper standard in admitting into evidence a statement to the police and a signed photographic array by a deceased eyewitness identifying Defendant as the shooter; (2) there was sufficient evidence to support the trial court's finding that Defendant had caused the death of the witness; and (3) even if the trial court improperly admitted evidence relating to the circumstances surrounding the death of the witness to show consciousness of guilt, the impropriety was harmless. View "State v. Thompson" on Justia Law