Justia Connecticut Supreme Court Opinion Summaries
Articles Posted in Constitutional Law
State v. Miguel C.
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
State v. Rose
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
State v. Thompson
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
State v. Santiago
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
State v. Golodner
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
State v. Pascual
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
State v. Otto
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
State v. Jordan
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
State v. Benton
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
418 Meadow St. Assocs., LLC v. Clean Air Partners, LLC
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