Justia Connecticut Supreme Court Opinion Summaries

Articles Posted in Constitutional Law
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The Supreme Court affirmed the judgment of the appellate court affirming Defendant's conviction of murder, holding that the appellate court did not err.On appeal, the appellate court concluded that the trial court had not abused its discretion in joining Defendant's case with the codefendant's case and that Defendant's right to confrontation was not violated when the trial court allowed a state's firearms examiner to testify about the findings of a second firearms examiner. The Supreme Court affirmed, holding (1) the appellate court did not err in determining that the trial court's joinder of Defendant's and his codefendant's cases was proper; (2) the admission of CSLI information into evidence was not error; and (3) the appellate court did not err by not determining that Defendant's right to confrontation was not violated by the challenged testimony, but the violation was harmless beyond a reasonable doubt. View "State v. Tyus" on Justia Law

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The Supreme Court affirmed the judgment of the habeas court denying in part Petitioner's petition for a writ of habeas corpus, holding that the habeas court correctly concluded that Petitioner did not demonstrate that he had suffered prejudice from the ineffective assistance of his trial counsel.Petitioner, a citizen of Jamaica who held a valid green card, pleaded guilty, pursuant to the Alford doctrine, to risk of injury to a child and strangulation in the third degree. The federal government subsequently initiated removal proceedings against Petitioner based, in part, on his conviction of risk of injury to a child. Petitioner filed a petition for a writ of habeas corpus, alleging ineffective assistance of counsel alleging that he would have gone to trial had his trial counsel not performed deficiently. The habeas court denied the petition as to the claim at issue in this appeal. The Supreme Court affirmed, holding that Petitioner did not meet his burden of establishing that there was a reasonable probability that he would have rejected the plea offer and proceeded to trial. View "Grant v. Commissioner of Correction" on Justia Law

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The Supreme Court affirmed the judgment of the trial court convicting Defendant of felony murder and other crimes, holding that there was no error or abuse of discretion in the proceedings below.Specifically, the Supreme Court held that the trial court (1) Defendant failed to establish under the third prong of State v. Golding, 567 A.2d 823 (Conn. 1989), that the trial court violated his federal due process rights by detaining three eyewitnesses to secure their attendance at trial; and (2) did not abuse its discretion by permitting the prosecutor to read passages from the witnesses' grand jury transcripts to the jury for substantive purposes pursuant to State v. Whelan, 513 A.2d 86 (Conn. 1986). View "State v. Gray" on Justia Law

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The Supreme Court reversed the judgment of the appellate court reversing the judgments of the trial court revoking Defendant's probation pursuant to Conn. Gen. Stat. 53a.32, holding that Defendant's conduct leading to the revocation was not entitled to First Amendment protection.After an escalated emotional confrontation with the staff of his child's preschool the trial court found that the State had met its burden of proving, by a preponderance of the evidence, that Defendant had violated the standard terms of his probation by violating Conn. Gen. Stat. 53a-181(a). On appeal, Defendant argued that his remarks warranted First Amendment protection because the State's evidence was insufficient to establish that his remarks constituted a true threat. The appellate court agreed and reversed. The Supreme Court reversed, holding that the appellate court erred in concluding that Defendant's remarks warranted First Amendment protection. View "State v. Taveras" on Justia Law

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The Supreme Court affirmed the judgment of the trial court convicting Defendant of sexual assault in the first and fourth degree, attempt to commit sexual assault in the first degree, and two counts of risk of injury to a child, holding that there was no error in the proceedings below.On appeal, Defendant argued (1) the trial court erred in overruling his objection brought pursuant to Batson v. Kentucky, 476 U.S. 79 (1986), objecting to the prosecutor's exercise of peremptory challenges to two prospective members of the jury; and (2) his conviction for risk of injury to a child violated constitutional double jeopardy protections. The Supreme Court affirmed, holding (1) the trial court did not commit clear error in determining that Defendant failed to meet his burden of proving by a preponderance of the evidence that the jury selection process in his case was tainted by purposeful discrimination; and (2) Defendant's conviction for two counts of risk of injury did not violate his right to be free from double jeopardy. View "State v. Jose A.B." on Justia Law

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The Supreme Court affirmed the judgment of the appellate court concluding that Defendant's confrontation rights were not violated by the admission into evidence of a codefendant's dual inculpatory statement to a fellow inmate acting at the behest of the state police, holding that there was no error.Defendant was convicted by a jury of murder, home invasion, burglary, and other crimes. The appellate court affirmed. At issue before the Supreme Court was whether the appellate court correctly concluded that the admission of the codefendant's dual inculpatory statement did not violate Defendant's confrontation rights under either the United States or Connecticut constitutions. The Supreme Court affirmed, holding that there was no error in the proceedings below. View "State v. Patel" on Justia Law

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The Supreme Court affirmed the judgment of the appellate court affirming the trial court's judgments following Defendant's conditional pleas of nolo contendere to charges of sale of a controlled substance and violation of probation, holding that Defendant could not meet the requirements to establish classical aggrievement.On appeal, Defendant, who was Caucasian, argued that his conviction violated his right to due process because the statute under which he was convicted violates the Equal Protection Clause of the United States Constitution because it was enacted to discriminate against African Americans and Mexican Americans. The appellate court affirmed, ruling that Defendant could not bring his constitutional challenge in his individual capacity based on the alleged violation of others' equal protection rights. The Supreme Court affirmed, holding that Defendant failed to meet the requirements to establish classical aggrievement. View "State v. Bradley" on Justia Law

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The Supreme Court reversed the judgment of the appellate court affirming Defendant's conviction, holding that the warrantless canine sniff conducted by law enforcement officers of the exterior door to a motel room for the purpose of detecting the presence of illegal drugs inside the room violated the warrant requirement of Conn. Const. Art. I, 7.After Defendant was charged with several drug-related offenses he filed a motion to suppress the evidence that had been seized from his motel room pursuant to a search warrant. The trial court denied the motion. Thereafter, Defendant entered a conditional plea of solo contenders. The appellate court affirmed. The Supreme Court reversed, holding that the appellate court erred in concluding (1) the canine sniff was not a search that violated Defendant's rights under article 1, section 7; and (2) the visual sweep of Defendant's motel room was justified by the exigencies of the situation. The Court remanded the case for further proceedings. View "State v. Correa" on Justia Law

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The Supreme Court reversed the judgment of the appellate court affirming Defendant's conviction of assault of a disabled person in the second degree, holding that Conn. Gen. Stat. 53a-60b(a)(1) and Conn. Gen. Stat. 1-1f(b) are unconstitutionally over inclusive and lack any rational basis as applied to assaults on persons whose physical disabilities neither diminish their ability to defend themselves from assault nor make them particularly vulnerable to injury.Defendant's conviction stemmed from an altercation with her sister, who suffered from fibromyalgia and other physical ailments, with a wooden billy club. On appeal from her conviction, Defendant argued that the statutes were unconstitutional vague as applied to her conduct and that the evidence did not support a finding that the victim was disabled. The appellate court affirmed. The Supreme Court reversed and remanded the case for a new trial, holding (1) sections 53a-60b(a)(1) and 1-1f(b) are not unconstitutionally vague; but (2) section 53a-60b(a)(1) is unconstitutionally overinclusive. View "State v. Jodi D." on Justia Law

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The Supreme Court affirmed the judgment of the appellate court concluding that the trial court's instructions in this criminal case, while improper, did not impact Defendant's due process right to a fair trial, holding that the appellate court did not err.Defendant was convicted of three counts of robbery in the first degree, two counts of felony murder, and other offenses for her involvement in two murders. The appellate court affirmed, holding that the trial court's instructions on robbery and felony murder were improper but provided the jury with a legally valid but factually unsupported basis for finding Defendant guilty. The Supreme Court affirmed, holding (1) the trial court's instructions provided the jury with a legally valid and factually supported alternative basis for finding Defendant guilty of robbery and felony murder; and (2) therefore, Defendant could not establish that the trial court's error more probably than not affected the jury's verdict. View "State v. Turner" on Justia Law