Justia Connecticut Supreme Court Opinion Summaries

Articles Posted in Constitutional Law
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In this case a jury found that Marc Pascual hired Defendant Eduardo Santiago to murder the victim and that Defendant acted in concert with Matthew Tyrell to break into the victim's home and fatally shoot him. The jury then returned a verdict finding Defendant guilty of all the charged offenses in the ten count information, including capital felony. The trial court sentenced Defendant to death by lethal injection. The Supreme Court (1) affirmed the underlying judgment of conviction; but (2) reversed the judgment insofar as it imposed a sentence of death, holding that the trial court did not err when it reviewed the department of children and families' file in camera, but the scope of its review failed to disclose significant and relevant mitigating evidence, requiring that Defendant receive a new penalty phase hearing. Remanded to the trial court for a new penalty phase hearing, following a new in camera review of the department's files and disclosure of evidence material to Defendant's case in mitigation. View "State v. Santiago" on Justia Law

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Following a jury trial, Defendant Daniel Golodner was convicted of two counts of interfering with an officer and two counts of reckless endangerment in the second degree in connection with a dispute over a neighbor's attempt to have their common property boundary surveyed. The Supreme Court affirmed the judgment in part and reversed the judgment in part with respect to the conviction on the second charge of reckless endangerment, holding that the trial court improperly denied Defendant's motion to dismiss the second charge of reckless endangerment for violation of the statute of limitations. Remanded with direction to render judgment of acquittal on that charge and for resentencing. View "State v. Golodner" on Justia Law

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After a jury trial, Defendant Francisco Pascual was convicted of several charges relating to his alleged attempt to sexually assault a twelve-year-old girl from El Salvador after the victim illegally crossed the border from Mexico into the United States. Defendant appealed, claiming that the trial court improperly (1) admitted hearsay evidence that, several days before the charged events, the victim was told about a threat made by an unidentified third party, and (2) instructed the jury that the threat evidence was admitted to show that the victim reasonably feared Defendant in order to prove sexual assault and kidnapping charges. The Supreme Court affirmed, holding that, even if the trial court improperly admitted the evidence and gave improper instructions to the jury, Defendant was not entitled to a new trial because the purported improprieties were not harmful. View "State v. Pascual" on Justia Law

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Following a jury trial, Defendant Kenneth John Otto, Sr. was convicted of murder and tampering with evidence. Defendant appealed. The Supreme Court affirmed the judgment of the trial court, holding (1) there was sufficient evidence to prove the element of specific intent necessary to support the murder conviction; and (2) in closing arguments the prosecutor did not improperly invite the jury to apply an incorrect legal standard or improperly suggest that the jury could find Defendant guilty of murder even if it did not find that he had the requisite intent to kill, simply to punish him for destroying evidence. View "State v. Otto" on Justia Law

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Defendant Victor Jordan was convicted of reckless endangerment in the first degree. The appellate court affirmed, concluding (1) Defendant's request to represent himself was not clear and unequivocal, and (2) Defendant's right to cross-examine a witness was not improperly restricted. The Supreme Court reversed, holding (1) Defendant in this case clearly and unequivocally asserted his Sixth Amendment right to self-representation, and the trial court's denial of Defendant's request without canvassing him was a violation of that right; and (2) the trial court did not improperly restrict Defendant's cross-examination of the witness. Remanded for a new trial on the charge of reckless endangerment in the first degree. View "State v. Jordan" on Justia Law

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Defendant Torrence Benton was convicted on charges of carrying a pistol without a permit and criminal possession of a pistol or revolver. Defendant appealed, claiming that the trial court improperly denied his motion to suppress evidence obtained in a search incident to his arrest. Specifically, Defendant contended that police seized him prior to his arrest without reasonable and articulable suspicion that he was engaged in criminal activity. The Supreme Court affirmed, holding that the totality of the circumstances in this case furnished sufficient reasonable and articulable suspicion that Defendant was engaged in criminal activity to justify the police stopping him. View "State v. Benton" on Justia Law

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Plaintiff, an LLC, owned and managed a commercial office building, and Defendant, an LLC, leased and occupied space in the building. A dispute arose between Plaintiff and Defendant over the scope of the lease and payment of rent. This dispute resulted in two people who had ownership interests in Plaintiff bringing the present action, in the name of Plaintiff, against Defendant to enforce the lease and to collect rent. Barbara Levine, who had fifty percent interest in Plaintiff and was the wife of a part owner of Defendant, disapproved of the lawsuit. The trial court rendered judgment for Defendant. The court of appeals affirmed, concluding that Plaintiff lacked standing to bring the action, since one of its member's votes should not have been excluded pursuant to Conn. Gen. Stat. 34-187(b) on the ground that she had an interest in the outcome of the suit that was adverse to the interest of Plaintiff. The Supreme Court reversed, holding that Plaintiff properly excluded Levine from voting her interest in determining whether to bring the present action because her interest in the outcome of the action was adverse to that of Plaintiff's in light of her husband's ownership interest in Defendant. View "418 Meadow St. Assocs., LLC v. Clean Air Partners, LLC" on Justia Law

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Plaintiff Luis Patino commenced this action against Defendant, his former employer, claiming that Defendant engaged in a discriminatory employment practice when it permitted his coworkers to harass him based on his sexual orientation over a period of many years. Following a jury trial, the jury returned a verdict in favor of Plaintiff, and the trial court entered a judgment in accordance with the verdict. The Supreme Court affirmed, holding (1) Conn. Gen. Stat. 46a-81c(1) provides for hostile work environment claims where employees are subject to sexual orientation discrimination; (2) Plaintiff presented sufficient evidence to support the jury's finding of a hostile work environment; and (3) the award of damages was supported by the evidence. View "Patino v. Birken Mfg. Co." on Justia Law

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Plaintiff G. Berry Schumann, a twelve year employee of Defendant, Dianon Systems, brought a complaint against Defendant alleging a violation of Conn. Gen. Stat. 31-51q and common-law wrongful termination of employment for an adverse employment action Defendant took against Plaintiff in response to speech made during the course of Plaintiff's job duties. The trial court found in favor of Plaintiff. At issue on appeal was whether the rule in Garcetti v. Ceballos, which states that public employees who make statements pursuant to their official duties are not insulated from employer discipline for First Amendment purposes, is applicable in an action brought against a private employer pursuant to section 31-51q. The Supreme Court reversed, holding (1) the rule in Garcetti applies to claims under section 31-51q grounded in the First Amendment that are brought against private employers; and (2) Plaintiff's speech was in the course of his employment duties for Defendant and, therefore, was not entitled to First Amendment protection under Garcetti. Remanded with direction to render judgment for Defendant on the claim under section 31-51q and for a new trial limited to Plaintiff's common-law wrongful termination claim. View "Schumann v. Dianon Sys., Inc." on Justia Law

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Plaintiff Carmen Perez-Dickson brought this action claiming that Defendants, the city board of education, the former assistant superintendent of the school district, and the former acting superintendent of the school district, disciplined her for exercising her right to free speech protected by the state and federal Constitutions in violation of Conn. Gen. Stat. 31-51q and 17a-101e, discriminated against her on the basis of her race, and intentionally caused her severe emotional distress. The jury returned a verdict in favor of Plaintiff on all counts. The Supreme Court reversed, holding (1) Defendants did not violate section 31-51q because any relevant speech by Plaintiff had been pursuant to her official job duties and such speech is not protected by the First Amendment; (2) Plaintiff failed to prove her claim of racial discrimination; and (3) Plaintiff failed to prove that Defendants had intentionally inflicted severe emotional distress on her. Remanded with direction to render judgment for Defendants. View "Perez-Dickson v. City of Bridgeport" on Justia Law