Justia Connecticut Supreme Court Opinion Summaries

Articles Posted in Criminal Law
by
The Supreme Court reversed the judgment of the habeas court denying Petitioner's amended petition for a writ of habeas corpus, holding that Petitioner's classification as a sex offender violated his right to procedural due process under both the federal constitution and Conn. Const. art. I, 9.In his habeas corpus petition, Petitioner alleged that the Commissioner of Correction violated his right to procedural due process in classifying him as a sex offender and that the habeas court erred in determining that the challenged classification did not violate his right to substantive due process or his right not to be punished "except in cases clearly warranted by law," under article first, section nine. The Supreme Court reversed, holding that Petitioner's classification as a sex offender violated his right to procedural due process. View "Anthony A. v. Commissioner of Correction" on Justia Law

Posted in: Criminal Law
by
The Supreme Court reversed the judgment of the appellate court affirming Defendant's conviction of risk of injury to a child, holding that the trial court abused its discretion by limiting Defendant's direct examination of himself and that the error was harmful.During trial, Defendant represented himself. On appeal, Defendant argued that the trial court erred in excluding testimony pertaining to his justification defense. The appellate court affirmed the convictions. The Supreme Court reversed, holding that the trial court abused its discretion in precluding Defendant's testimony, in which he attempted to testify about information crucial to his justification defense, and that the error was harmful. View "State v. Mark T." on Justia Law

Posted in: Criminal Law
by
The Supreme Court affirmed the judgment of the appellate court affirming Defendant's conviction of murder and related offenses, holding that the appellate court correctly concluded that the trial court's rejection of Defendant's insanity defense was reasonable.On appeal, Defendant argued that the trial court improperly rejected the opinions of his experts. Specifically, Defendant argued that the State neither presented nor elicited evidence to undermine the consensus of his experts that, as the result of a mental disease, Defendant lacked substantial capacity to control his conduct within the requirements of the law. The appellate court affirmed. The Supreme Court affirmed, holding that the appellate court did not err in concluding that the trial court's rejection of his expert opinion was not arbitrary. View "State v. Weathers" on Justia Law

Posted in: Criminal Law
by
The Supreme Court affirmed the judgment of the appellate court reversing the judgment of the habeas court denying Appellant's petition for a writ of habeas corpus and ordering a new trial on certain charges, holding that the trial court committed an error under State v. Salomon, 949 A.2d 1092 (Conn. 2008), and that the error was not harmless.At issue in this appeal and the companion case decided today, see Banks v. Commissioner of Correction, __ A.3d __ (Conn. 2021), was how the harmlessness of a Salamon error is to be assessed. In Salamon, the Supreme Court held that, when a defendant is charged with kidnapping in conjunction with another underlying crime, the defendant is entitled to a jury instruction that he cannot be convicted of kidnapping if the restraint imposed on the victim was merely incidental or necessary to the underlying crime. Here, Appellant forcibly moved and restrained his victims after having taken property in their possession. The Supreme Court affirmed the judgment of the appellate court granting Appellant's habeas petition and ordering a new trial on the kidnapping charges, holding that this Court had no fair assurance that the Salamon error in this case did not have a substantial and injurious effect or influence in determining the jury's verdict. View "Bell v. Commissioner of Correction" on Justia Law

Posted in: Criminal Law
by
In this case, the Supreme Court resolved two questions left open by State v. Salamon, 949 A.2d 1092 (Conn. 2008) and its progeny, holding that that standard articulated in Brecht v. Abrahamson, 507 U.S. 6019 (1993), which governs federal habeas actions, applies in state habeas proceedings as well.In Salamon, the Supreme Court overruled its longstanding interpretation of Connecticut's kidnapping statutes and held that, when a defendant is charged with kidnapping in conjunction with another underlying crime, the defendant is entitled to a jury instruction that he cannot be convicted of kidnapping if the restraint imposed on the victim was merely incidental or necessary to the underlying crime. In the instant case, Appellant was found guilty of four counts of kidnapping in the first degree and four counts of robbery. After the Supreme Court decided Salamon, Appellant filed a petition for a writ of habeas corpus arguing that the instructions given to the jury were not in accordance with Salamon. The habeas court denied the petition. The appellate court reversed. The Supreme Court affirmed, holding (1) the Brecht standard applied in this case; and (2) the habeas court correctly determined that the trial court's failure to instruct Appellant's jury in accordance with Salamon was harmless. View "Banks v. Commissioner of Correction" on Justia Law

Posted in: Criminal Law
by
The Supreme Court affirmed Defendant's conviction of two counts of interfering with an officer, in violation of Conn. Gen. Stat. 53a-167a(a), holding that there was no error in the proceedings below.At issue on appeal was whether the trial court erred in denying Defendant's pretrial motion to suppress on the grounds that he was seized in violation of the Fourth Amendment when a marked police cruiser blocked the egress of his vehicle, which was parked with its engine running and Defendant asleep in the driver's seat. The Supreme Court affirmed, holding that no violation of the Fourth Amendment occurred because the responding officer was checking on Defendant's well-being pursuant to the officer's community caretaking function and was not engaged in an investigatory stop involving criminal activity. View "State v. Pompei" on Justia Law

by
The Supreme Court affirmed Defendant's conviction of three counts of first degree sexual assault and three counts of risk of injury to a child, holding that there was no error in the proceedings below.Specifically, the Supreme Court held (1) the prosecutor did not engage in prosecutorial impropriety in her questioning of the victim; (2) the prosecutor did not engage in prosecutorial impropriety during closing and rebuttal arguments; and (3) the trial court did not violate Conn. Gen. Stat. 54-84(b) or infringe on Defendant's constitutional right to remain silent when it denied his request to instruct the jury that he elected not to testify and instead referred to his failure to testify. View "State v. Michael T." on Justia Law

by
The Supreme Court affirmed the judgment of the appellate court affirming the trial court's denial of Defendant's motion to correct an illegal sentence, holding that the trial court properly denied the motion.Defendant was convicted of murder and sentenced to fifty years of incarceration. In his motion to correct an illegal sentence, Defendant argued that the sentencing court substantially relied on materially inaccurate information concerning both his criminal history and the particular manner in which he committed the criminal offense. The trial court denied the motion, and the appellate court affirmed. The Supreme Court affirmed, holding that the appellate court correctly concluded that the trial court did not abuse its discretion in denying Defendant's motion to correct an illegal sentence. View "State v. Francis" on Justia Law

Posted in: Criminal Law
by
The Supreme Court affirmed the judgment of the trial court convicting Defendant of six counts of capital felony, among other crimes, holding that Connecticut's individual voir dire process protected Defendant's right to a fair trial by assessing and mitigating the prejudicial effects of pretrial publicity about this notorious case.The State charged Defendant with six counts of capital felony, three counts of murder, four counts of kidnapping, and other crimes. Following extensive pretrial motions practice, Defendant's case was tried to a jury, which returned a guilty verdict on all counts. The trial court subsequently sentenced Defendant to six consecutive death sentences. On appeal, Defendant claimed, among other allegations of error, that the trial court improperly denied his motion to change the venue of his trial given the effects of prejudicial pretrial publicity. The Supreme Court affirmed, holding (1) the pretrial publicity did not result in actual jury prejudice that deprived Defendant of a fair trial; and (2) Defendant was not entitled to relief on his remaining allegations of error. View "State v. Komisarjevsky" on Justia Law

by
The Supreme Court remanded this case to the trial court for further proceedings, holding that the trial court erred by failing to inquire into defense counsel's alleged conflict of interest.Defendant was convicted of one count of murder and sentenced to fifty years of imprisonment. On appeal, Defendant argued that his federal constitutional right to the effective assistance of counsel was violated during trial when the court denied his motions to dismiss his counsel without adequately inquiring into certain bases for his motions and when the court failed to conduct any inquiry into defense counsel's alleged conflict of interest. The Supreme Court affirmed, holding that the trial court inadequately inquired into the bases for Defendant's motions to dismiss defense counsel. View "State v. Davis" on Justia Law