Justia Connecticut Supreme Court Opinion Summaries

The defendant was convicted of murder and carrying a pistol or revolver without a permit. The key evidence against him included two recorded police interviews with Daequan Carr, the state's primary witness, who identified the defendant as the shooter. Carr was uncooperative at trial, leading the prosecution to introduce his prior statements under the Whelan rule, which allows prior inconsistent statements to be used substantively if certain conditions are met.The trial court admitted Carr's interviews, finding his trial testimony inconsistent with his prior statements. Carr's father, Dennis Cobia, also made statements during one interview, which the court allowed to the extent Carr adopted them. The jury found the defendant guilty, and he was sentenced to fifty-five years in prison.The defendant appealed, arguing that Carr's trial testimony was not inconsistent with his prior statements and that the trial court erred in admitting Cobia's statements. He also contended that the court improperly admitted a Facebook photo and Snapchat video showing him with items similar to those used in the crime.The Connecticut Supreme Court found that the trial court abused its discretion in admitting Carr's interviews. Carr's ambiguous statements about his recollection did not clearly establish inconsistency, and the prosecution did not sufficiently probe his memory or attempt to refresh it. The court also failed to adequately determine whether Carr refused to testify. The error was not harmless, as Carr's identification of the defendant was crucial, and no other evidence directly linked the defendant to the crime.The court clarified that adopted statements could be admitted under Whelan if unequivocally adopted by the witness. However, the trial court improperly delegated to the jury the task of determining which of Cobia's statements were adopted by Carr. The court upheld the admission of the Facebook photo and Snapchat video, finding their probative value outweighed any prejudicial effect.The judgment was reversed, and the case was remanded for a new trial. View "State v. Hamilton" on Justia Law

The defendant was convicted of murder after fatally stabbing his girlfriend in their shared apartment. The incident occurred while the victim’s son was home, though he did not witness the attack. After the killing, the defendant fled in the victim’s car and communicated with family members via Facebook, making statements about the altercation and his intent to leave the country. He was later apprehended in New York, where he made statements to police both spontaneously and during a subsequent interview, in which he confessed to the killing. During the police interview, photographs were taken of the defendant to document any injuries.In the Superior Court for the judicial district of Waterbury, the defendant moved to suppress his statement to the Waterbury police, arguing it was obtained in violation of his right to counsel under Miranda and Edwards. The trial court agreed in part, suppressing the statement from the prosecution’s case-in-chief but allowing its use for impeachment if the defendant testified, relying on State v. Reid. The court also admitted photographs taken of the defendant, finding they were obtained through standard police procedure and not as a result of the Miranda violation. Additionally, the court permitted the late disclosure of a witness, the victim’s sister-in-law, after finding no prejudice to the defense.The Connecticut Supreme Court affirmed the conviction. It held that the state constitution does not prohibit the use of a voluntary statement obtained in violation of Miranda for impeachment purposes, declining to overrule State v. Reid. The court also held that the photographs were admissible because they had an independent source in routine police procedure. Finally, the court found no abuse of discretion or violation of the defendant’s right to a fair trial in allowing the late-disclosed witness to testify, as the defendant suffered no demonstrable prejudice. View "State v. Haynes" on Justia Law

The case involved a fatal stabbing that occurred during a confrontation inside the victim’s apartment. The defendant and the victim were both acquainted with a woman named Menendez, who had relationships with both men. In the period leading up to the incident, the defendant became increasingly controlling and jealous regarding Menendez’s interactions with the victim. On the day of the stabbing, Menendez was staying with the victim, and after a series of tense interactions and text messages, the defendant arrived at the victim’s apartment. Shortly after the defendant’s arrival, a violent altercation ensued, resulting in the victim being stabbed in the chest and later dying from his injuries. The defendant admitted to stabbing the victim but claimed he acted in self-defense, asserting that the victim attacked him with a knife first.The case was tried before the Superior Court in the judicial district of Hartford. At trial, the state presented testimony from Menendez, a medical examiner, a detective, and an inmate who had shared a cell with the defendant. The state’s evidence included testimony that contradicted the defendant’s account, suggesting that the defendant brought the knife to the apartment and was the only person armed during the struggle. The jury found the defendant guilty of murder, rejecting his self-defense claim. The defendant was sentenced to thirty-five years of incarceration and appealed his conviction, arguing that the evidence was insufficient to disprove his claim of self-defense beyond a reasonable doubt.The Connecticut Supreme Court reviewed the case. The court held that the state presented sufficient evidence for the jury to find, beyond a reasonable doubt, that the defendant either did not actually believe he was in imminent danger of deadly physical force or, if he did, that such a belief was not objectively reasonable. The court affirmed the conviction, concluding that the state met its burden of disproving the defendant’s justification defense. View "State v. Ramsey" on Justia Law

The defendant was convicted of felony murder and attempted robbery in the first degree, among other charges, following an incident where another individual, Christian, shot and killed the victim, Rodney, during a scuffle that ensued after the defendant attempted to rob Rivera. The defendant appealed, arguing that the state needed to prove that Christian was an accessory to the attempted robbery to secure a felony murder conviction.The trial court had instructed the jury on the felony murder statute, which does not require the state to prove that a participant in the crime was an accessory. The defendant was found guilty of felony murder, attempted robbery, and firearm offenses, but not guilty of murder as an accessory. The trial court vacated the manslaughter conviction on double jeopardy grounds and sentenced the defendant to forty years in prison.The Connecticut Supreme Court reviewed the case and held that the felony murder statute does not require the state to establish that a participant who caused the death was an accessory to the predicate felony. The court found sufficient evidence to support the conviction, noting that Christian's actions were in furtherance of the attempted robbery and that the killing occurred during the continuous sequence of events surrounding the attempted robbery.The court also rejected the defendant's claim of instructional error, as the trial court's instructions were legally proper and did not need to include a requirement for proving accessorial liability. Additionally, the court found that the defendant had waived his confrontation clause claim by not objecting to the admission of Rivera's video-recorded interviews at trial.Finally, the court declined to overrule its precedent in State v. Newsome, which allows a reliable out-of-court statement to serve as the sole evidentiary basis for a conviction. The court concluded that Rivera's statements were reliable and corroborated by other evidence, thus sufficient to establish the defendant's intent to commit attempted robbery.The judgment of the trial court was affirmed. View "State v. Hinton" on Justia Law

The plaintiff in error, Gregory Johnson, challenged his summary conviction of three counts of criminal contempt for repeatedly interrupting and directing racial slurs and other profanities at the court during his habeas corpus trial. He claimed that the trial court deprived him of his right to due process by not postponing the contempt proceeding and by not ordering it to be held before a different judge.The trial court, acting in the capacity of a trial court for the habeas proceeding, conducted the first day of the trial on April 4, 2023, and resumed on May 4, 2023. The plaintiff, appearing virtually, refused to comply with the court's instructions, used racial slurs, and swore at the court. The court warned the plaintiff multiple times before finding him in contempt. The court then appointed counsel for the plaintiff, allowed a private consultation, and provided an opportunity for both the plaintiff and his counsel to speak before sentencing.The Connecticut Supreme Court reviewed the case and found that the trial court's summary contempt proceeding substantially complied with the requirements of Practice Book § 1-16, which ensures fairness in the adjudication of summary criminal contempt. The court concluded that the plaintiff's behavior obstructed the orderly administration of justice, justifying the trial court's decision not to defer the proceeding under Practice Book § 1-17. The court also determined that the trial judge did not become personally embroiled in the controversy, as the judge maintained a calm demeanor and provided the plaintiff with multiple warnings and opportunities to explain his behavior.The court rejected the plaintiff's claim that his medical issues and alleged incompetency warranted deferral of the contempt proceeding. The trial court had observed the plaintiff's behavior and found him competent, and his counsel did not request a competency evaluation. The Connecticut Supreme Court dismissed the writ of error, upholding the trial court's findings and sentencing. View "Johnson v. Superior Court" on Justia Law

The defendant was convicted of manslaughter in the first degree with a firearm, criminal possession of a firearm, criminal possession of ammunition, and carrying a pistol without a permit. The incident involved the defendant shooting and killing a bystander while returning fire at an individual who had shot at him first. The defendant argued that the trial court improperly declined to instruct the jury on self-defense for the manslaughter charge and that his convictions for both criminal possession of a firearm and ammunition violated double jeopardy.The trial court instructed the jury on self-defense for the murder charge but not for the manslaughter charge. The jury found the defendant not guilty of murder but guilty of manslaughter in the first degree with a firearm. The court found the defendant guilty of the remaining charges in a bench trial.The Connecticut Supreme Court reviewed the case and concluded that the trial court erred in not providing a self-defense instruction for the manslaughter charge. The court held that self-defense is a justification defense applicable to reckless manslaughter, regardless of whether the victim is a bystander or the aggressor. The court emphasized that the jury should have been allowed to consider whether the defendant's actions were justified under the circumstances. The court also found that the trial court's failure to provide a self-defense instruction was not harmless beyond a reasonable doubt, as it was the sole issue in the case.Additionally, the court held that the defendant's conviction for both criminal possession of a firearm and criminal possession of ammunition violated double jeopardy. The court concluded that the legislature did not intend to treat the possession of a firearm and the ammunition within it as separate crimes when both are used during a single incident. Therefore, the court vacated the defendant's conviction for criminal possession of ammunition.The Connecticut Supreme Court reversed the conviction for manslaughter in the first degree with a firearm and remanded the case for a new trial on that charge. The court vacated the conviction for criminal possession of ammunition and affirmed the judgment in all other respects. View "State v. Williams" on Justia Law

The defendant was convicted of unlawful restraint in the second degree, sexual assault in the fourth degree, attempt to commit sexual assault in the third degree, and sexual assault in the third degree. The charges stemmed from an incident where the defendant allegedly assaulted the victim, C, in his home. C testified that the defendant made unwanted advances, restrained her, and sexually assaulted her. The defendant argued that C fabricated the story due to a rent dispute between the defendant and C's mother, K.The trial court found the defendant guilty on all charges, and the Appellate Court affirmed the conviction. The defendant appealed, claiming that the prosecutor's remarks during rebuttal closing argument were improper and deprived him of a fair trial. Specifically, the prosecutor listed common defenses in criminal cases and referred to the "nuts and sluts" defenses in sexual assault cases, suggesting that C would have to be "nuts" to fabricate her story.The Supreme Court of Connecticut reviewed the case and determined that the prosecutor's use of the phrase "nuts and sluts" was improper as it appealed to the jurors' emotions and diverted their attention from the evidence. The court also found that the prosecutor's listing of defenses was improper because it was unrelated to the evidence presented at trial. However, the court concluded that these improprieties did not deprive the defendant of a fair trial.The court applied the factors from State v. Williams to assess the impact of the improprieties. It found that the prosecutor's statements were not severe, were infrequent, and the state's case was relatively strong. The court also noted that defense counsel did not object to the statements or request curative instructions. As a result, the Supreme Court of Connecticut affirmed the judgment of the Appellate Court. View "State v. Sullivan" on Justia Law

The defendant was convicted of risk of injury to a child in 2012 and sentenced to fifteen years of incarceration, execution suspended after five years, followed by twenty-five years of probation. As a condition of his probation, the court prohibited him from contacting the victim. In 2021, the state sought a standing criminal protective order against the defendant, which the trial court granted, requiring the defendant to have no contact with the victim and to remain at least 100 yards away from her, among other conditions. The order was set to remain in effect for forty years.The defendant appealed to the Appellate Court, arguing that the trial court abused its discretion by issuing the protective order without evidence of a change in circumstances since his sentencing. The Appellate Court majority upheld the trial court’s decision, concluding that the defendant did not challenge the imposition of the order on the ground that the court failed to abide by the statutory standard. The dissenting judge disagreed, interpreting the defendant’s argument as asserting that the statute required evidence of a change in circumstances.The Supreme Court of Connecticut reviewed the case and concluded that the defendant adequately briefed his claim that additional requirements apply when a standing criminal protective order is issued postsentencing. The court held that, in addition to the express requirements of § 53a-40e (a), the issuing court must find that additional evidence, not presented at sentencing, indicates that the order will best serve the interests of the victim and the public. The trial court failed to apply this standard, as it did not find that the defendant had been convicted of a qualifying offense or that additional evidence supported the issuance of the order. Consequently, the Supreme Court reversed the Appellate Court’s judgment and remanded the case with direction to vacate the trial court’s order. View "State v. Mieles" on Justia Law

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