Justia Connecticut Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the appellate court affirming the trial court's judgment resentencing Defendant for crimes he committed when he was seventeen years old, holding that Conn. Gen. Stat. 54-91g did not apply to Defendant.This case arose from the carjacking, kidnapping, and murder of the victim by Defendant and another individual. Defendant was tried as an adult under the then applicable law and sentenced to life imprisonment without the possibility parole. Later changes in juvenile sentencing law prompted the resentencing proceedings at issue on appeal. Defendant filed a motion to correct an illegal sentence, which the trial court granted, sentencing Defendant to a total effective sentence of eighty years' imprisonment. Defendant appealed, arguing that the trial court had failed to adhere to the requirements of section 54-91g. The Supreme Court affirmed, holding that section 54-91g did not apply to Defendant. View "State v. Coltherst" on Justia Law

The Supreme Court affirmed the judgment of the appellate court affirming the trial court's judgments following Defendant's conditional pleas of nolo contendere to charges of sale of a controlled substance and violation of probation, holding that Defendant could not meet the requirements to establish classical aggrievement.On appeal, Defendant, who was Caucasian, argued that his conviction violated his right to due process because the statute under which he was convicted violates the Equal Protection Clause of the United States Constitution because it was enacted to discriminate against African Americans and Mexican Americans. The appellate court affirmed, ruling that Defendant could not bring his constitutional challenge in his individual capacity based on the alleged violation of others' equal protection rights. The Supreme Court affirmed, holding that Defendant failed to meet the requirements to establish classical aggrievement. View "State v. Bradley" on Justia Law

The Supreme Court affirmed the decision of the trial court granting Defendant's motion to dismiss the information against him, holding that the trial court did not err in concluding that the statute of limitations was not tolled by Conn. Gen. Stat. 54-193(c).Defendant was charged with possession of child pornography in the first degree. Pursuant to a warrant, Defendant was arrested nearly five years after the warrant was issued and more than three years after the applicable statute of limitations had expired. The trial court granted Defendant's motion to dismiss, concluding (1) the tolling provision of section 54-193(c) was inapplicable once the warrant was issued within the limitation period, and (2) the almost five-year delay in executing the warrant was unreasonable under State v. Crawford, 521 A.2d 1034 (Conn. 1987). The Supreme Court affirmed, holding that although section 54-193 (c) tolls the limitation period within which a prosecution may be commenced, Crawford and its progeny establish that, once an arrest warrant has been issued, the State must serve the warrant without undue delay. View "State v. A.B." on Justia Law

The Supreme Court reversed the judgment of the trial court convicting Defendant of four counts of patronizing a prostitute and one count of trafficking in persons as an accessory, holding that the state presented insufficient evidence to convict Defendant of any of the charged counts.On appeal, Defendant claimed, among other things, that the state presented insufficient evidence for a reasonable jury to have concluded that he knew or reasonably should have known that the men with whom he engaged in sexual conduct for a fee were victims of trafficking. The Supreme Court reversed, holding (1) there was insufficient evidence to convict Defendant of the crime of patronizing a prostitution; and (2) the evidence was insufficient to prove Defendant was guilty of the crime of trafficking in persons as an accessory because the state did not prove that he had the specific intent necessary for accessorial liability for the crime of trafficking in persons. View "State v. Bemer" on Justia Law

The Supreme Court affirmed Defendant's conviction of two counts of murder, holding that Defendant was entitled to relief on her argument that no rational finder of fact reasonably could have rejected her insanity defense on the present factual records.Specifically, the Supreme Court held that the trier of fact reasonably credited the State's expert testimony presented to rebut Defendant's insanity defense that, at the time Defendant murdered her two children, she was not suffering from a mental disease or defect, was able to appreciate the wrongfulness of her conduct, and was able to conform her conduct to the requirements of law. View "State v. LeRoya M." on Justia Law

The Supreme Court reversed the judgment of the appellate court affirming Defendant's conviction, holding that the warrantless canine sniff conducted by law enforcement officers of the exterior door to a motel room for the purpose of detecting the presence of illegal drugs inside the room violated the warrant requirement of Conn. Const. Art. I, 7.After Defendant was charged with several drug-related offenses he filed a motion to suppress the evidence that had been seized from his motel room pursuant to a search warrant. The trial court denied the motion. Thereafter, Defendant entered a conditional plea of solo contenders. The appellate court affirmed. The Supreme Court reversed, holding that the appellate court erred in concluding (1) the canine sniff was not a search that violated Defendant's rights under article 1, section 7; and (2) the visual sweep of Defendant's motel room was justified by the exigencies of the situation. The Court remanded the case for further proceedings. View "State v. Correa" on Justia Law

The Supreme Court affirmed Defendant's conviction of murder and carrying a pistol without a permit, holding that while evidence regarding a defendant's gang affiliation may prejudice a jury against a defendant, there was no prejudicial error in this case.On appeal, Defendant argued that the trial court erred in admitting certain evidence, including police photographs arguably reflecting Defendant's gang membership. The Supreme Court affirmed, holding (1) any error in the trial court's admission of expert testimony regarding local street gangs was harmless beyond a reasonable doubt; (2) the trial court did not abuse its discretion in admitting the photographs at issue; and (3) Defendant's remaining evidentiary arguments were unavailing. View "State v. Tomlinson" on Justia Law

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