Justia Connecticut Supreme Court Opinion Summaries

The defendant was on probation after being convicted of conspiracy to commit murder. His probation was revoked based on allegations that he participated in a home invasion, left the state without permission, and failed to submit to substance abuse evaluations and counseling. The defendant contested the revocation, particularly challenging the admission of an out-of-court identification by a witness, Rainey, who was unavailable for cross-examination.The trial court admitted Rainey’s identification without applying the balancing test required by State v. Crespo, which weighs the defendant’s right to confront witnesses against the state’s reasons for not producing the witness and the reliability of the evidence. The court found the defendant violated his probation and imposed a thirteen-year sentence. The defendant appealed, arguing the trial court erred by not applying the Crespo balancing test.The Appellate Court affirmed the trial court’s decision, concluding that the defendant had abandoned his request for the Crespo balancing test during the probation revocation hearing. The defendant then appealed to the Connecticut Supreme Court.The Connecticut Supreme Court found that the defendant did not abandon his Crespo claim. The court noted that the defendant consistently argued for the application of the Crespo balancing test and that the trial court should have engaged in this balancing before admitting Rainey’s identification. The Supreme Court reversed the Appellate Court’s judgment in part and remanded the case for a new probation revocation hearing limited to determining whether the defendant was involved in the home invasion. The findings that the defendant violated other conditions of his probation were upheld and not to be relitigated. View "State v. Wade" on Justia Law

The defendant was convicted of murder and criminal violation of a standing criminal protective order. During the trial, the defendant elected to represent himself. However, the trial court reappointed his former standby counsel to represent him due to the defendant's conduct, including his conscious decision not to appear in court on a particular occasion.The trial court found that the defendant's conduct, which included refusing court-ordered transportation, failing to appear at scheduled hearings, and threatening to leave trial proceedings, constituted a forfeiture of his right to self-representation. The trial court noted that the defendant's behavior was dilatory, disruptive, and manipulative. The trial court reappointed standby counsel to regain control of the courtroom and the trial schedule.The Connecticut Supreme Court reviewed the case and affirmed the trial court's decision. The Supreme Court held that the trial court did not violate the defendant's right to self-representation. The court found that the defendant's conduct, including his refusal to return to court after a lunch break, was sufficiently disruptive and obstructionist to warrant a forfeiture of his right to self-representation. The court emphasized that the trial court had warned the defendant about the consequences of his actions and had given him multiple opportunities to conform to the rules before making the forfeiture finding. The Supreme Court concluded that the trial court properly exercised its discretion to reappoint counsel to ensure a fair trial. View "State v. Petteway" on Justia Law

The defendant was convicted of murder, tampering with or fabricating physical evidence, and making a false statement in connection with the shooting death of his wife. He allegedly staged the crime scene to resemble a home invasion. The defendant appealed, claiming multiple instances of prosecutorial impropriety deprived him of a fair trial.In the lower court, the trial court denied the defendant’s motion to preclude certain evidence and denied in part his motion to suppress certain statements. The trial court also admitted data from the victim’s Fitbit after a Porter hearing, finding the evidence scientifically reliable. The jury found the defendant guilty on all counts, and the trial court sentenced him to sixty-five years of imprisonment.The Connecticut Supreme Court reviewed the case and found four instances of prosecutorial impropriety: (1) the prosecutor’s failure to rephrase a question about a "mini Cheshire scene," (2) asking the defendant if he planned to kill the victim during a trip to Vermont, (3) stating that the defendant was counting on the jury to be gullible, lazy, and unintelligent, and (4) failing to disclose an expert witness’s anticipated testimony. However, the court concluded that these improprieties did not deprive the defendant of a fair trial, either individually or collectively.The court also held that the trial court did not abuse its discretion in admitting the Fitbit data, as the evidence was scientifically reliable. Additionally, the court found that the defendant was not in custody during his hospital interview for purposes of Miranda, and thus, the trial court properly denied the motion to suppress his statement.The Connecticut Supreme Court affirmed the judgment of the trial court. View "State v. Dabate" on Justia Law

The defendant was convicted of assault in the first degree for stabbing the victim. The key facts of the case include the defendant and the victim having a history of domestic violence, with the defendant previously assaulting the victim. On the day of the incident, the victim was stabbed multiple times while entering her home. The victim identified the defendant as her attacker, and the police arrested him based on this identification and other circumstantial evidence.The trial court admitted evidence of two prior incidents where the defendant had physically assaulted the victim to establish his specific intent to cause serious bodily injury. The defendant objected, arguing that the evidence was irrelevant and highly prejudicial. The trial court allowed the evidence, and the jury found the defendant guilty. The defendant appealed, claiming that the trial court abused its discretion in admitting the prior misconduct evidence.The Appellate Court affirmed the trial court's decision, concluding that the prior misconduct evidence was relevant to the defendant's intent and that its probative value outweighed its prejudicial effect. The court also found that any error in admitting the evidence was harmless given the strength of the state's case and the limiting instructions provided to the jury.The Supreme Court of Connecticut reversed the Appellate Court's judgment, holding that the trial court abused its discretion in admitting the prior misconduct evidence. The court found that the probative value of the evidence did not outweigh its prejudicial effect, as the key issue at trial was the identity of the attacker, not the intent. The court also determined that the admission of the prior misconduct evidence was harmful because it presupposed the defendant's identity as the attacker and the remaining evidence was equivocal. The case was remanded for a new trial. View "State v. Marcello E." on Justia Law

The defendant was convicted of murder in connection with the shooting death of the victim. The victim was shot while talking to her boyfriend outside her apartment building. The defendant, along with two other individuals, fired several shots toward the victim’s residence, and one bullet struck the victim in the head, causing her death. The initial investigation did not result in charges, but years later, new information from witnesses led to the defendant’s arrest.The Superior Court in the judicial district of Hartford tried the case, and the jury found the defendant guilty of murder. The defendant appealed, claiming that the trial court improperly admitted evidence of his alleged gang affiliation and his actions after law enforcement attempted to arrest him. The trial court had allowed the gang affiliation evidence to establish a motive for the shooting and admitted evidence of the defendant’s evasive conduct as indicative of his consciousness of guilt.The Supreme Court of Connecticut reviewed the case and held that the trial court did not abuse its discretion in admitting the gang affiliation evidence, as it was relevant to establishing a motive for the shooting and its probative value outweighed any unfair prejudicial impact. The court also found that the trial court properly admitted evidence of the defendant’s evasive conduct after law enforcement attempted to arrest him, as it was probative of the defendant’s consciousness of guilt. The court affirmed the judgment of the trial court. View "State v. Jones" on Justia Law

The case involves the defendant, who was convicted of multiple counts of sexual assault in the first degree and risk of injury to a child. The victims, D and T, were sexually abused by the defendant, who was in a relationship with their mother, Q, and lived with them for several years. The abuse began when the victims were five years old and continued until they were eleven. The victims disclosed the abuse to their mother years later, which led to the defendant's arrest and trial.In the trial court, the defendant was found guilty on five counts of sexual assault in the first degree and eight counts of risk of injury to a child. The trial court instructed the jury, based on the precedent set in State v. Daniel W. E., that the victims' delay in reporting the abuse should not be considered when evaluating their credibility. The defendant appealed, arguing that this instruction violated his due process rights and that the trial court abused its discretion by allowing certain testimony from D.The Supreme Court of Connecticut reviewed the case and overruled the portion of Daniel W. E. that modified the constancy of accusation doctrine. The court returned to the standard set in State v. Troupe, which allows constancy evidence to corroborate the victim's testimony but not for substantive purposes, and permits the jury to consider the victim's delay in reporting when evaluating credibility. The court concluded that the trial court's instruction was erroneous but harmless, as it was not reasonably probable that the instruction misled the jury.Additionally, the court held that the trial court did not abuse its discretion in allowing D to testify that the defendant told her he played the same sexual "games" with his daughter, as this testimony was probative of the defendant's grooming behavior. The judgment of the trial court was affirmed. View "State v. Adam P." on Justia Law

The defendant was convicted of the murder of her minor son, E, and arson in the second degree. The case arose from an incident where the defendant sedated E with a substantial amount of diphenhydramine, set two fires in their home, and was found unconscious alongside E, who was later pronounced dead. The medical examiner determined E's cause of death to be homicidal asphyxia, with diphenhydramine intoxication as a contributing factor. The defendant's social media posts prior to the incident indicated distress and potential premeditation.The trial court, after a competency hearing, found the defendant competent to stand trial. The jury found the defendant guilty of both charges. The defendant appealed, claiming her amnesia deprived her of a fair trial, the trial court improperly admitted social media posts, and the evidence was insufficient to support her convictions.The Connecticut Supreme Court reviewed the case. It held that the defendant's claim of amnesia affecting her right to a fair trial failed under the first prong of State v. Golding because she did not request a posttrial determination regarding the fairness of the trial, making the record inadequate for review. The court also found that the trial court did not abuse its discretion in admitting the social media posts, as they were properly authenticated through testimony.Regarding the sufficiency of the evidence, the court concluded that the evidence was sufficient to support the defendant's conviction of murder. The jury could reasonably find that the defendant caused E's death with intent, based on the cumulative evidence, including the circumstances of the fire, the sedative found in E's system, and the defendant's behavior and social media posts. The evidence was also sufficient to support the arson conviction, as the jury could reasonably find that the defendant set the fires with the intent to damage the home and conceal the murder. The court affirmed the judgment. View "State v. Ziolkowski" on Justia Law

The defendant was convicted of possessing child pornography in the first degree, which requires proof of possessing fifty or more images of child pornography. The New Britain Police Department obtained a search warrant for the defendant’s cell phone, which revealed images of suspected child pornography. The state introduced fifty-seven images at trial, and the defendant was found guilty by a jury.The defendant appealed, arguing that thirteen of the images did not constitute child pornography as they depicted mere nudity, which is protected under the First Amendment. He also contended that the trial court improperly instructed the jury on the Dost factors, which are used to determine whether an image depicts a lascivious exhibition of the genitals or pubic area. The trial court had instructed the jury that it could consider these factors but was not obligated to do so.The Connecticut Supreme Court reviewed the case and concluded that at least eleven of the thirteen challenged images depicted a lascivious exhibition of the genitals or pubic area, thus constituting child pornography. The court also determined that the first five Dost factors are helpful in assessing whether a depiction is lascivious but should not be used to define the term. The sixth Dost factor, which considers whether the image is intended to elicit a sexual response in the viewer, should not be used in possession cases as it introduces a subjective element.The court found that the trial court’s instruction on the Dost factors, including the sixth factor, did not mislead the jury. The court also held that a specific unanimity instruction was not required, as the different images and categories of sexually explicit conduct are merely means of proving the elements of the offense. The court affirmed the trial court’s decision to admit exhibits showing file names of deleted images associated with the defendant’s email address, as they were probative of the defendant’s knowledge and possession of child pornography. The judgment was affirmed. View "State v. Inzitari" on Justia Law

The defendant was convicted of two counts of murder and one count of assault in the first degree, among other crimes, related to a shooting incident involving multiple victims. The defendant claimed self-defense and defense of others, arguing that he shot one of the victims, Wooten, because Wooten was an active shooter. The defendant also sought to admit evidence of another victim, Taylor's, prior arson conviction to demonstrate Taylor's violent character.At trial, the defendant testified that he shot Taylor and Wooten in self-defense and defense of others. The jury found the defendant guilty of all charges, rejecting his justification defenses. The trial court excluded evidence of Taylor's arson conviction, ruling that the defendant did not have a certified copy of the conviction.The Connecticut Supreme Court reviewed the case. The court held that the evidence was sufficient to defeat the defendant's claims of self-defense and defense of others regarding Wooten's murder. The court noted that the shootings of Taylor, Smith, and Wooten were part of a single, continuous episode. The jury could reasonably have found that Wooten was acting defensively to protect Smith from the defendant's unprovoked attack. The court also held that any error in excluding evidence of Taylor's arson conviction was harmless. The arson conviction did not necessarily involve a risk of harm to a person or violent physical conduct, and there was no evidence that Taylor was armed or the aggressor in the shootings. The court affirmed the trial court's judgment. View "State v. Johnson" on Justia Law

The defendant was convicted of three counts of sexual assault in the first degree. He appealed, arguing that the second count in the state's February 2020 substitute information was time-barred by the five-year statute of limitations. This count alleged conduct from January 1, 2014, which was first included in the 2020 substitute information, more than five years after the alleged conduct occurred.The trial court denied the defendant's motion to dismiss, reasoning that the defendant had notice of the 2014 allegations from the arrest warrant affidavit filed in 2018. The Appellate Court affirmed the trial court's decision, agreeing that the arrest warrant affidavit provided sufficient notice of the 2014 conduct, and thus, the 2020 substitute information did not substantially broaden or amend the timely charges.The Supreme Court of Connecticut reviewed the case and concluded that the arrest warrant affidavit does not toll the statute of limitations for uncharged conduct. The court held that the timely filed 2018 informations did not mention the 2014 conduct, and the defendant did not receive notice within the limitation period that he would be called to defend against the 2014 conduct. Therefore, count two of the 2020 substitute information substantially broadened or amended the timely charges and was time-barred under the statute of limitations.The Supreme Court reversed the Appellate Court's judgment regarding count two, directing the trial court to render a judgment of acquittal on that count and to resentence the defendant on the remaining counts. The judgment was affirmed in all other respects. View "State v. Orane C." on Justia Law