Justia Connecticut Supreme Court Opinion Summaries

Articles Posted in Criminal Law
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The Supreme Court affirmed the judgment of the appellate court affirming Defendant's conviction of strangulation in the second degree and assault in the third degree, holding that there was no error in the trial court's evidentiary rulings and that there was no reason to mandate Defendant's requested jury instruction.Defendant was convicted of strangulation in the second degree and assault in the third degree. The appellate court affirmed the convictions. The Supreme Court affirmed, holding (1) the appellate court did not err in upholding the trial court's decision to admit into evidence a written statement that Defendant made during a custodial interrogation; and (2) this Court declines Defendant's request to exercise its supervisory authority to require trial court, in cases in which the police fail to record an interrogation in violation of Conn. Gen. Stat. 54-lo(h), to instruct the jury that the police violated the law. View "State v. Christopher S." on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the decision of the appellate court affirming the judgment of the trial court convicting Defendant of three counts of sexual assault in the first degree and other crimes, holding that neither the structure nor the content of the prosecutor's closing argument deprived Defendant of his constitutional rights.On appeal, Defendant argued that the prosecutor deprived him of his constitutional rights to present a closing argument and to a fair trial by reserving her analysis of certain evidence for the rebuttal portion of closing argument and by mischaracterizing other evidence during rebuttal. The appellate court affirmed. The Supreme Court affirmed, holding that Defendant's claims of prosecutorial impropriety failed. View "State v. Gonzalez" on Justia Law

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The Supreme Court affirmed the judgment of the Appellate Court dismissing Petitioner's appeal from the trial court's denial of his request for leave to file a late petition for certification to appeal from the court's judgment denying his petition for a new trial, holding that the trial court did not abuse its discretion in concluding that certification to appeal should be denied.The trial court denied Petitioner's petition on the ground that Petitioner's claims were "meritless and too late." Petitioner appealed, claiming that the trial court improperly considered the merits of the petition rather than the reasons for the delay or other factors relevant to permitting a late filing. The Appellate Court dismissed Petitioner's appeal. The Supreme Court affirmed, holding that the trial court (1) abused its discretion by failing to engage in the proper analysis to determine whether to excuse the late petition for certification; and (2) did not abuse its discretion in determining that the petition failed to raise issues warranting certification. View "Mitchell v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the judgment of the appellate court, which affirmed the judgment of the habeas court denying Petitioner's amended petition for a writ of habeas corpus, holding that Petitioner failed to demonstrate that he was prejudiced by his trial counsel's failure to object to the prosecutor's improper comments during closing argument at Petitioner's criminal trial.Petitioner was convicted of murder. On appeal, the appellate court concluded that at least one of the prosecutor's comments during closing argument violated Petitioner's constitutional right to a fair trial but that Petitioner had not been prejudiced by the improper remarks. The Supreme Court affirmed, holding that the failure to Petitioner's criminal trial counsel to object to the prosecutor's improper remarks did not undermine the Court's confidence in the verdict. View "Ross v. Commissioner of Correction" on Justia Law

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The Supreme Court affirmed the judgment of the trial court revoking Defendant's probation and sentencing him to an effective term of imprisonment of two years, holding that the trial court did not err in denying Defendant's motion to dismiss the violation of probation charge.Defendant pleaded guilty to illegal possession of child pornography in the second degree. After Defendant was released on probation he was charged with violating his probation for failing to complete sex offender treatment. The trial court found that Defendant had violated his probation, revoked his probation, and sentenced him to a term of imprisonment of six years. Defendant appealed, arguing that the condition of probation on which the violation of probation charge was predicated violated his Fourteenth Amendment rights to due process and equal protection and the constitutional prohibition against the imposition of cruel and unusual punishment. The Supreme Court affirmed, holding that Defendant's claims of error lacked merit. View "State v. Imperiale" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the judgment of the appellate court affirming Defendant's conviction of sexually assaulting a twelve-year-old girl and sentencing him to a total effective prison term of thirty-three years, holding that there was no error.On appeal, Defendant argued that the trial court violated his due process right at sentencing by increasing his sentence because of his unwillingness to apologize to the victims. The appellate court affirmed, holding that the record did not support Defendant's contention. The Supreme Court affirmed, holding that the prison term imposed on Defendant did not give rise to an inference that the court punished him for refusing to issue an apology to the victims. View "State v. Angel M." on Justia Law

Posted in: Criminal Law
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The Supreme Court reversed the judgment of the appellate court reversing the judgment of the trial court convicting Defendant of burglary in the third degree, attempt to commit tampering with physical evidence, and attempt to commit arson in the second degree, holding that the appellate court improperly addressed an issue of evidentiary sufficiency sua sponte without calling for supplemental briefing.The appellate court reversed Defendant's conviction on the ground that there was insufficient evidence for the jury to have reasonably concluded that Defendant intended to tamper with physical evidence. The Supreme Court reversed, holding that the appellate court improperly decided an issue of evidentiary sufficiency sue sponte without ordering supplemental briefing, as required by Blumberg Associates Worldwide, Inc. v. Brown & Brown of Connecticut, Inc., 84 A.3d 840 (Conn. 2014). View "State v. Stephenson" on Justia Law

Posted in: Criminal Law
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The Supreme Court reversed the judgment of the appellate court affirming Defendant's conviction of assault in the second degree, holding that the appellate court erred in determining that the trial court's investigative inadequacy jury instruction did not mislead the jury or otherwise deprive Defendant of his right to present an investigative inadequacy defense.The jury found Defendant guilty of assault in the second degree, and the court rendered judgment in accordance with the verdict. On appeal, Defendant argued that the jury instructions deprived him of his right to present a defense of investigative inadequacy. The appellate court rejected Defendant's claim and affirmed. The Supreme Court reversed, holding (1) the model jury instruction utilized by the trial court in this case failed properly to instruct the jury; and (2) the instructional error was not harmless. View "State v. Gomes" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the judgment of the appellate court determining that Public Acts, Spec. Session, June 2015, No. 15-2, 1 (Spec. Sess. P.A. 15-2) does not apply retroactively, holding that the plain language of Spec. Sess. P.A. 15-2, 1 clearly and unambiguously prohibits retroactive application.Defendant was found guilty of one count of possession of less than four ounces of a cannabis-type substance and of two counts of possession of narcotics. Defendant filed a motion to correct an illegal sentence, which the trial court denied. The appellate court affirmed. Defendant appealed, arguing that a prospective-only application of the amendment would lead to an absurd or unworkable result and, alternatively, that the Supreme Court should adopt the amelioration doctrine. The Supreme Court affirmed and declined the invitation to adopt the amelioration doctrine, holding that the amendment does not apply retroactively and that this conclusion does not lead to an absurd or unworkable result. View "State v. Bischoff" on Justia Law

Posted in: Criminal Law
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The Supreme Court reversed the judgment of the appellate court affirming the judgment of the trial court denying Defendant's motion to correct an illegal sentence, holding that the trial court lacked subject matter jurisdiction to entertain Defendant's motion because the motion sought only to modify Defendant's conviction, not his sentence.Defendant was convicted of felony murder and manslaughter. The trial court merged the conviction for manslaughter with the felony murder conviction for sentencing purposes. In his motion to correct an illegal sentence, Defendant argued that his sentence was illegal under the supervisory rule set forth in State v. Polanco, 61 A.3d 1084 (2013). The trial court concluded that Polanco did not apply retroactively and denied the motion. The appellate court affirmed. The Supreme Court reversed, holding that the trial court lacked jurisdiction to entertain Defendant's motion to correct an illegal sentence. View "State v. Smith" on Justia Law