Justia Connecticut Supreme Court Opinion Summaries

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

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

The Supreme Court affirmed the judgment of the trial court convicting Defendant of two counts of assault in the second degree, holding that the trial court did not commit reversible error.Specifically, the Supreme Court held (1) there was sufficient evidence to sustain the jury’s verdict of guilty of assault in the second degree; (2) the trial court did not err in denying Defendant’s request to cross-examine the victim more extensively regarding her pending civil action against Defendant arising out of the same incident; and (3) the trial court did not abuse its discretion in allowing a paramedic, testifying as a fact witness, to testify regarding symptoms of a concussion. View "State v. Fisher" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of murder and criminal possession of a pistol or revolver, holding that any error in the proceedings below was harmless.Specifically, the Supreme Court held (1) the trial court acted within its discretion in admitting testimony from four lay witnesses identifying Defendant in video surveillance footage; (2) the trial court properly admitted expert testimony regarding an enhancement of the video surveillance footage, and any error in the court's conclusion that defense counsel had opened the door to certain testimony elicited during the prosecutor’s redirect examination of the expert was harmless; (3) the trial court properly denied Defendant’s request for a special credibility instruction as to a witness whom Defendant claimed should have been treated as a jailhouse informant; (4) any error in the trial court's admission of identifications of Defendant made by Nigel Watts was harmless; and (5) there was sufficient evidence to support Defendant's conviction for criminal possession of a pistol or revolver. View "State v. Bruny" on Justia Law

The Supreme Court amended section 7-3(a) to the Connecticut Code of Evidence to incorporate an exception for testimony relating to the identification of persons depicted in surveillance video or photographs and affirmed the judgment of the trial court in this case, holding that the amendment did not affect the result in this appeal.After a jury trial, Defendant was found guilty of murder and criminal possession of a firearm. At issue on appeal was the wisdom of the "ultimate issue rule" as applied to lay witness identifications of persons depicted in video surveillance footage. The Supreme Court affirmed Defendant's convictions, holding (1) section 7-3(a) of the Connecticut Code of Evidence is hereby amended to incorporate an exception to the ultimate issue rule for lay opinion testimony that relates to the identification of persons depicted in surveillance video or photographs; (2) State v. Finan, 881 A.2d 187 (Conn. 2005), is hereby overruled; and (3) this Court adopts a totality of the circumstances test for determining whether lay opinion testimony identifying a person in surveillance video or photographs is admissible. View "State v. Gore" on Justia Law

The Supreme Court reversed the judgment of the trial court denying Defendant's motion to correct an illegal sentence, holding that the trial court abused its discretion by denying Defendant's motion to correct.Defendant, a juvenile offender, was convicted of two counts each of kidnapping in the first degree and sexual assault in the first degree, among other offenses. The sentencing court imposed a total effective sentence of sixty years of incarceration. Relying on later changes to juvenile sentencing law, Defendant filed a motion to correct an illegal sentence. The trial court rejected Defendant's claims. The Supreme Court reversed, holding (1) the sentencing court substantially relied on a materially false and unreliable theory; and (2) therefore, Defendant's sentence was imposed in an illegal manner in violation of his right to due process, and the trial court erred in denying Defendant's motion to correct. View "State v. Belcher" on Justia Law

The Supreme Court reversed the judgment of the trial court determining that Defendant had engaged in criminal conduct while he was on probation by possessing a firearm that was capable of discharging a shot and thus revoking Defendant's probation, holding that the evidence was insufficient to establish that the airlift pellet gun found in Defendant's residence was a firearm as defined by Conn. Gen. Stat. 53a-3(19).At issue was whether the State presented sufficient evidence at the violation of probation hearing in this case to establish that the airlift pellet gun found in Defendant's residence fell under the definition of a firearm. The Supreme Court concluded that it did not, holding that the trial court's factual finding that the airlift pellet gun was a "weapon" capable of firing a shot for the purpose of the definition of "firearm" under section 53a-3(19) was clearly erroneous. View "State v. Lopez" on Justia Law

The Supreme Court denied Petitioner's petition for certification to appeal the appellate court's dismissal of his appeal from the judgment of the habeas court declining to issue a writ of habeas corpus, holding that the habeas court did not abuse its discretion in denying certification to appeal.Petitioner filed a petition for a writ of habeas corpus challenging his conviction of sexual assault in the second degree. The habeas court declined to issue the writ on the ground that Petitioner was not in the custody of the Commissioner of Correction. Thereafter, Petitioner filed a petition for certification to appeal, which the habeas court denied. The appellate court dismissed Petitioner's appeal on the ground that he failed in his appellate court brief to brief the claim that the habeas court had abused its discretion in denying his petition for certification to appeal. The Supreme Court affirmed, holding that a petition must at least expressly allege and explain in his brief how the habeas court abused its discretion in denying certification. View "Goguen v. Commissioner of Correction" on Justia Law

The Supreme Court affirmed Defendant's convictions of manslaughter in the first degree with a firearm and criminal possession of a firearm, holding that the trial court did not err or abuse its discretion.During his first trial, the jury found Defendant guilty of murder but rejected his claim of self-defense. Defendant was found guilty of criminal possession of a firearm in a subsequent trial in connection with the same incident. The Supreme Court affirmed, holding (1) the evidence was sufficient to disprove Defendant's claim of self-defense beyond a reasonable doubt; and (2) the trial court correctly concluded that any juror misconduct caused no actual prejudice to Defendant and thus did not err in denying Defendant's motion for a new trial. View "State v. Hughes" on Justia Law

The Supreme Court affirmed the decision of the appellate court reversing the judgment of the habeas court granting Petitioner's petition for a writ of habeas corpus, holding that Petitioner failed to satisfy his burden under Strickland v. Washington, 466 U.S. 668 (1984), to establish his claims of ineffective assistance of counsel.Petitioner was convicted of manslaughter in the first degree with a firearm and sentenced to forty years' imprisonment with respect to this charge. In his habeas petition, Petitioner argued, among other things, that his trial counsel provided ineffective assistance by failing to call six additional eyewitnesses to testify at the underlying criminal trial. The habeas court granted relief. The appellate court reversed. The Supreme Court affirmed, holding that Petitioner failed to show prejudice on either of his ineffective assistance of counsel claims. View "Jordan v. Commissioner of Correction" on Justia Law