Justia Connecticut Supreme Court Opinion Summaries

Articles Posted in Criminal Law
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The Supreme Court affirmed Defendant's conviction of murder in violation of Conn. Gen. Stat. 53a-54a, holding that the trial court did not abuse its discretion by admitting evidence of uncharged misconduct, namely, two prior shootings involving the alleged murder weapon, to prove identity and means.On appeal, Defendant argued that the evidence was not relevant or material to identity and that the probative value of the evidence was outweighed by its prejudicial effect. The Supreme Court disagreed and affirmed, holding that, given the manner in which the testimony was limited and the numerous cautionary instructions given to the jurors, the trial court did not abuse its discretion in admitting the uncharged misconduct evidence. View "State v. Patterson" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed in part and reversed in part the judgment of the trial convicting Defendant of various crimes arising from five criminal cases, which included first degree robbery, second degree arson, and attempt to commit murder, holding that the trial court erred in denying Defendant's motion to suppress.At issue on appeal was the trial court's denial of Defendant's motion to suppress evidence discovered during a search of his cell phone and evidence obtained from his cell phone service provider. Specifically in question was whether the warrants authorizing those searches were supported by probable cause and whether they particularly described the place to be searched and the things to be seized. The Supreme Court reversed in part, holding (1) the trial court erred in denying Defendant's motion to suppress the information obtained from the execution of both warrants; and (2) this error was harmless with respect to some, but not all, of the crimes alleged in the indictment. View "State v. Smith" on Justia Law

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The Supreme Court affirmed the judgment of the trial court convicting Defendant of felony murder, robbery in the first degree, and other crimes, holding that any error in the trial court's failure to suppress evidence obtained from a search warrant was harmless.On appeal, Defendant challenged the trial court's denial of his motion to suppress evidence obtained from a search of his cell phone, arguing that the application for the warrant authorizing the search lacked a particular description of the items to be seized and that the affidavit supporting the application failed to establish probable cause. The Supreme Court affirmed, holding that the State met its burden of showing that any error in the denial of Defendant's motion to suppress was harmless beyond a reasonable doubt. View "State v. Bowden" on Justia Law

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The Supreme Court affirmed Defendant's convictions of murder, assault in the first degree by means of the discharge of a firearm, and attempt to commit assault in the first degree by means of the discharge of a firearm, holding that there was no violation of Defendant's Fourth Amendment rights in this case.On appeal, Defendant argued that the trial court erred in denying his motion to suppress evidence seized from his father on the grounds that the police officers' warrantless entry into the residence home under the emergency exception to the Fourth Amendment warrant requirement was justified. Alternatively, the court deterred that, even if the initial entry was unlawful, Defendant's shooting of the victim sufficiently attenuated that unlawful act from the subsequent lawful search and seizure of the evidence at issue. The Supreme Court affirmed, holding that (1) under the totality of the circumstances, it was objectively reasonable for the officers to conclude that there was an emergency justifying their initial entry into the residence; and (2) in light of this conclusion, the subsequent entries were similarly justified. View "State v. Samuolis" on Justia Law

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The Supreme Court affirmed the judgment of the trial court on remand determining that Defendant had failed to establish that defense counsel, Kirstin Coffin, had a conflict of interest, holding that there was no error.Defendant was convicted of murder and sentenced to a fifty-year term of incarceration. On appeal, the Supreme Court held that the trial court had a duty to inquire into Coffin's alleged conflict of interest and remanded for a determination as to whether Defendant's claim had merit. After a hearing on remand, the trial court concluded that Defendant had failed to establish that Coffin was burdened by an actual conflict of interest as a result of her prior representation of Defendant. The Supreme Court affirmed, holding (1) there was no error in the determination that Coffin was not burdened by an actual conflict of interest that adversely affected her performance; and (2) Defendant's remaining claim was without merit. View "State v. Davis" on Justia Law

Posted in: Criminal Law
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The Supreme Court dismissed as moot Defendant's appeal from the judgment of conviction, rendered after a jury trial, of murder and criminal possession of a firearm by a convicted felon, holding that Defendant was not entitled to relief.On appeal, Defendant argued that the trial court violated his Sixth Amendment right to present a defense by precluding an expert witness proffered by defense counsel from testifying as to Defendant's location during certain relevant time periods on the basis of cell phone carrier data. The Supreme Court dismissed Defendant's appeal, holding (1) Defendant failed to challenge all of the independent bases of the trial court's evidentiary ruling; and (2) therefore, this Court could not provide Defendant practical relief. View "State v. Council" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the judgment of the trial court denying Defendant's pretrial motion to dismiss for failure to prosecute him within the five-year limitation period set forth in Conn. Gen. Stat. 54-193a, holding that the trial court did not err.After a jury trial, Defendant was convicted of three counts of sexual assault in the first degree and one count of risk of injury to a child. On appeal, Defendant argued that the warrant for his arrest was not executed without unreasonable delay because the police did not execute the warrant until nearly sixteen years after its issuance. The Supreme Court affirmed, holding (1) Defendant did not satisfy his burden of establishing that he was available for arrest; and (2) therefore, the trial court properly denied Defendant's pretrial motion to dismiss the charges against him. View "State v. Juan F." on Justia Law

Posted in: Criminal Law
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The Supreme Court reversed the judgment of the trial court convicting Defendant of sexual assault in the first degree, attempt to commit sexual assault in the first degree, and risk of injury to a child, holding that the trial court abused its discretion in admitting irrelevant, uncharged misconduct evidence.At issue on appeal was whether the trial court abused its discretion in admitting uncharged misconduct evidence of alleged prior incidents of sexual abuse of Defendant against the complainant. The Supreme Court answered in the positive, holding (1) in a general intent crime case where the theory of defense is that the alleged conduct did not occur, rather than a theory of defense in which the conduct occurred unintentionally, uncharged misconduct is irrelevant and inadmissible to prove intent; and (2) the uncharged misconduct evidence in this case was irrelevant to the issue of intent and was therefore inadmissible. View "State v. Juan J." on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the judgment of the appellate court affirming the judgment of the trial court convicting Defendant of murder, conspiracy to commit assault in the first degree, and other crimes, holding that Defendant was not entitled to relief on his claims of error.Specifically, the Supreme Court held that the appellate court correctly concluded that the trial court had not abused its discretion by admitting an audio recording allegedly containing Defendant's confession into evidence and by directing the jury to disregard portions of defense counsel's closing argument. The Supreme Court affirmed, holding (1) the trial court did not abuse its discretion in admitting the audio recording into evidence; and (2) any error by the trial court in precluding certain arguments made by defense counsel was harmless. View "State v. Rivera" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the judgment of the appellate court affirming the trial court's judgment convicting Defendant of one count of murder, holding that Defendant was not entitled to relief on any of his allegations on appeal.Specifically, the Supreme Court held that the appellate court correctly concluded that the trial court (1) did not violate Defendant's Sixth Amendment right to present a defense by excluding from evidence a statement purportedly made by an unknown female bystander and an autopsy toxicology report; (2) did not violate Defendant's right to due process by declining to give a jury instruction on self-defense; and (3) did not abuse its discretion by declining to sanction the state for its late disclosure of the murder weapon and related expert reports by excluding this evidence or dismissing the murder charge. The Court further cautioned the State regarding the late disclosure of evidence. View "State v. Hargett" on Justia Law