Justia Connecticut Supreme Court Opinion Summaries

The Supreme Court reversed the judgment of the appellate court affirming Defendant's conviction of assault of a disabled person in the second degree, holding that Conn. Gen. Stat. 53a-60b(a)(1) and Conn. Gen. Stat. 1-1f(b) are unconstitutionally over inclusive and lack any rational basis as applied to assaults on persons whose physical disabilities neither diminish their ability to defend themselves from assault nor make them particularly vulnerable to injury.Defendant's conviction stemmed from an altercation with her sister, who suffered from fibromyalgia and other physical ailments, with a wooden billy club. On appeal from her conviction, Defendant argued that the statutes were unconstitutional vague as applied to her conduct and that the evidence did not support a finding that the victim was disabled. The appellate court affirmed. The Supreme Court reversed and remanded the case for a new trial, holding (1) sections 53a-60b(a)(1) and 1-1f(b) are not unconstitutionally vague; but (2) section 53a-60b(a)(1) is unconstitutionally overinclusive. View "State v. Jodi D." on Justia Law

The Supreme Court affirmed the judgment of the appellate court concluding that the trial court's instructions in this criminal case, while improper, did not impact Defendant's due process right to a fair trial, holding that the appellate court did not err.Defendant was convicted of three counts of robbery in the first degree, two counts of felony murder, and other offenses for her involvement in two murders. The appellate court affirmed, holding that the trial court's instructions on robbery and felony murder were improper but provided the jury with a legally valid but factually unsupported basis for finding Defendant guilty. The Supreme Court affirmed, holding (1) the trial court's instructions provided the jury with a legally valid and factually supported alternative basis for finding Defendant guilty of robbery and felony murder; and (2) therefore, Defendant could not establish that the trial court's error more probably than not affected the jury's verdict. View "State v. Turner" on Justia Law

The Supreme Court reversed the decision of the appellate court reversing the judgment of the trial court denying Defendant's motion to correct an illegal sentence on the basis of its conclusion that Defendant's convictions of manslaughter in the first degree and risk of injury to a child violate the constitutional prohibition against double jeopardy, holding that the appellate court erred.At issue on appeal was to what extent a court should consider the facts alleged in the charging documents when determining whether a crime is a lesser included offense of another rather than confining its analysis to the elements of the statutes at issue under Blockburger v. United States, 284 U.S. 299 (1932). The Supreme Court held that, insofar as risk of injury to a child is not a lesser included offense of manslaughter in the first degree, the appellate court improperly considered the facts alleged by the state in the information rather than confining its analysis under the Blockburger test. View "State v. Tinsley" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of felony murder, robbery in the first degree, conspiracy to commit robbery in the first degree, and criminal possession of a firearm, holding that Defendant's claims on appeal were unavailing.On appeal, Defendant argued that the trial court improperly admitted portions of a written statement from one of the state's witnesses and unduly restricted the cross-examination of another state witness. The Supreme Court affirmed, holding (1) Defendant failed to demonstrate that the admission of the witness's written statement substantially swayed the jury's verdict; and (2) assuming that partial restrictions placed on defense counsel's cross-examination of the second witness infringed on the minimum of cross-examination guaranteed by the Confrontation Clause of the Sixth Amendment, such infringement was harmless beyond a reasonable doubt. View "State v. Gibson" on Justia Law

The Supreme Court reversed in part the judgment of the trial court finding Defendant guilty of manslaughter in the first degree with a firearm and other offenses, holding that the trial court improperly admitted certain evidence.On appeal, Defendant argued that his statements to the police were improperly admitted into evidence because his constitutional rights were violated when the police continued to question him after he invoked his right to counsel pursuant to Miranda v. Arizona, 384 U.S. 436 (1966). Defendant further argued that the prosecutor committed improprieties during closing argument, depriving him of his right to a fair trial. The Supreme Court affirmed, holding (1) the admission of Defendant's written statement and a portion of a video recording of the interview with police should have been suppressed, and the error was not harmless as to Defendant's conviction of manslaughter in the first degree with a firearm; and (2) there was no other reversible error in this case. View "State v. Culbreath" on Justia Law

The Supreme Court reversed in part the judgment of the appellate court affirming Defendant's conviction of criminal possession of a pistol or revolver in violation of Conn. Gen. Stat. 53a-217c, holding that the appellate court erred in concluding that there was sufficient evidence to support the conviction.On appeal, Defendant claimed that there was insufficient evidence of his knowledge of the gun and no evidence to prove his dominion or control over it. The appellate court affirmed, concluding that there was sufficient circumstantial evidence to support the conviction. The Supreme Court reversed in part, holding that the evidence was insufficient to establish beyond a reasonable doubt that Defendant had knowledge of the gun and the intent to exercise dominion or control over it. View "State v. Dawson" on Justia Law

The Supreme Court reversed Defendant's conviction of one count of sexual assault in the first degree, holding that the trial court violated Defendant's Sixth Amendment right to the assistance of counsel.At issue on appeal was whether the trial court violated Defendant's constitutional right to effective assistance of counsel by precluding defense counsel from arguing during closing argument that the complainant, M., had planted physical evidence in an effort to prove her false allegations against Defendant. The Supreme Court agreed and reversed, holding that the trial court's limitation of the scope of defense counsel's closing argument deprived Defendant of his Sixth Amendment right to the assistance of counsel. View "State v. Robert R." on Justia Law

The Supreme Court affirmed the judgment of the appellate court that dismissed Petitioner's appeal from the order of the habeas court directing Petitioner to produce certain investigative materials contained in the file of his criminal defense attorneys, holding that there was no error.Petitioner pleaded guilty to murder and tampering with physical evidence. Petitioner later filed a petition for writ of habeas corpus, arguing that he had received ineffective assistance of counsel. Respondent filed a motion for the production of relevant materials from Petitioner's criminal defense and investigative files, which the habeas court granted. Petitioner appealed, and the appellate court dismissed the appeal for lack of a final judgment. The Supreme Court affirmed, holding that the appellate court properly dismissed Petitioner's appeal for lack of subject matter jurisdiction. View "Halladay v. Commissioner of Correction" on Justia Law

The Supreme Court affirmed Defendant's conviction of sexual assault in the third degree, sexual assault in the fourth degree, risk of injury to a child, and sexual assault in the first degree, holding that Defendant's claims on appeal lacked merit.Specifically, the Supreme Court held that (1) the trial court did not abuse its discretion in admitting into evidence a video recording of the victim's forensic interview under the medical treatment exception to the hearsay rule; (2) alleged prosecutorial impropriety did not deprive Defendant of a fair trial; (3) the evidence was sufficient to support the convictions; and (4) the statutes criminalizing sexual assault in the first degree and risk of injury to a child are not unconstitutionally vague as applied to Defendant's conduct. View "State v. Roy D. L." on Justia Law

The Supreme Court affirmed in part and reversed in part Defendant's convictions on charges arising from two separate incidents between him and officers of the Clinton Police Department in July 2015, holding that Defendant's conviction in the case relating to events of July 19, 2015 must be reversed and the conviction in the case relating to the events of July 22, 2015 is reversed with respect to one assault count.On appeal, Defendant argued (1) evidence of certain events during the first incident should have been suppressed because those events were the result of an unconstitutional investigatory detention, and (2) his convictions of two counts of assault of public safety personnel related to the second incident was infirm because the evidence was insufficient and the trial court erred in instructing the jury. The Supreme Court reversed in part, holding (1) the trial court erred in denying Defendant's motion to suppress; and (2) a new trial was required with respect to one of the assault charges due to instructional error. View "State v. Haughwout" on Justia Law