Justia Connecticut Supreme Court Opinion Summaries

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

The Supreme Court affirmed the judgment of the appellate court affirming Defendant's conviction of felony murder, holding that there was no error.On appeal, Defendant argued that the trial court erred in admitting testimony regarding the gang affiliations of Defendant and the State's relocation of the State's chief witness after the witness provided information to the police incriminating Defendant in the murder. Defendant further challenged other rulings involving the chief witness. The Supreme Court affirmed the appellate court's judgment denying Defendant's appeal, holding that the appellate court did not err in its resolution of the case. View "State v. Bermudez" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of manslaughter in the first degree, holding that the trial court did not abuse its discretion in admitting certain evidence.During trial and in an effort to support his self-defense theory, Defendant sought to admit evidence that the victim had searched an Internet shopping site for weapons in the days leading up to the incident in which Defendant fatally stabbed the victim. The trial court concluded that the evidence was not admissible, relevant or material and denied Defendant's motion in limine to admit the evidence. Defendant challenged this ruling on appeal, arguing that the evidence was both relevant and admissible as uncharged misconduct evidence. The Supreme Court disagreed, holding that the trial court did not abuse its discretion in declining to admit into evidence the victim's Internet searches for weapons. View "State v. Streit" on Justia Law

The Supreme Court reversed the judgment of the appellate court affirming the trial court's dismissal of Defendant's motion to correct a sentence imposed in an illegal manner, holding that the appellate court erred in concluding that the trial court lacked subject matter jurisdiction to correct the sentence.Defendant pleaded guilty to manslaughter in the first degree and assault in the first degree. The trial court sentenced him to a total term of twenty-five years of incarceration. Defendant later filed a motion to correct, arguing that the trial court imposed the sentence in an illegal manner. The trial court concluded that it lacked subject matter jurisdiction over his motion to correct on the ground that the motion constituted a collateral attack on Defendant's conviction, not his sentence. The appellate court affirmed, holding that Defendant had failed to raise a colorable claim within the scope of Practice Book 43-22. The Supreme Court reversed, holding (1) Defendant showed a possibility that a factual basis necessary to establish jurisdiction existed; and (2) therefore, the appellate court improperly affirmed the trial court's dismissal of Defendant's motion to correct. View "State v. Ward" on Justia Law