Justia Connecticut Supreme Court Opinion Summaries

Articles Posted in Criminal Law
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The Supreme Court affirmed the judgment of the appellate court affirming Defendant's conviction of murder as either a principal or as an accessory, holding that Defendant was not entitled to relief on any of his allegations of error.On appeal, Defendant argued that the appellate court abused its discretion by denying him permission to file a supplemental brief to raise a new claim pursuant to Carpenter v. United States, __ U.S. __ (2018) and incorrectly determined that his hearsay claim regarding the testimony of a key state witness was unpreserved. The Supreme Court affirmed, holding (1) the appellate court should have granted Defendant's motion to file a supplemental brief, but any error was harmless; and (2) the trial court properly admitted the challenged testimony as nonhearsay and, alternatively, any error was harmless. View "State v. Armadore" on Justia Law

Posted in: Criminal Law
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The Supreme Court reversed the sentence imposed upon Defendant in connection with his conviction of four counts of sexual assault in the first degree and three counts of risk of injury to a child, holding that the trial court improperly sentenced Defendant to a period of probation on each count of sexual assault, in violation of Conn. Gen. Stat. 53a-29(a).After a jury trial, Defendant was found guilty of sexually abusing his daughter. The trial court sentenced Defendant to twenty-five years of imprisonment, execution suspended after twenty years, and ten years of probation on each count of sexual assault and ten years of imprisonment on each count of risk of injury to a child. The sentences were imposed concurrently. The Supreme Court affirmed the convictions but reversed the sentence, holding (1) the trial court improperly imposed a period of probation on each of Defendant's four sexual assault convictions; and (2) Defendant's challenges to his conviction failed. View "State v. Jose R." on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the judgment of the appellate court affirming the decision of the trial court dismissing Plaintiff's declaratory judgment action for lack of subject matter jurisdiction, holding that the appellate court properly upheld the trial court's dismissal of the action as not ripe.Plaintiff, who was convicted of murder, has been incarcerated since 1990. Plaintiff brought this action seeking a judgment declaring that Conn. Gen. Stat. 54-125g was applicable to him and that the commissioner must factor his eligibility for early release in his time sheet. The trial court concluded that the issue raised by Plaintiff was not ripe. The appellate court affirmed. The Supreme Court affirmed, holding that Plaintiff's claims were nonjusticiable and that the trial court lacked subject matter jurisdiction on this alternative ground. View "Francis v. Board of Pardons & Paroles" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the judgment of the appellate court dismissing Petitioner's appeal from the judgment of the habeas court denying Petitioner's petition for a writ of habeas corpus, holding that Petitioner could not prevail on his claim of ineffective assistance of trial counsel.Petitioner was convicted of robbery in the first degree. Later, Petitioner filed a petition for a writ of habeas corpus, asserting that he had received ineffective assistance of counsel during plea negotiations prior to his trial. The appellate court dismissed the petition. The Supreme Court affirmed, holding that Petitioner failed to meet his burden of proving that his attorney did not adequately advise him of his maximum sentencing exposure if convicted of the lesser included offense of robbery in the third degree. View "Moore v. Commissioner of Correction" on Justia Law

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The Supreme Court affirmed the judgment of the appellate court affirming Defendant's conviction of strangulation in the second degree and assault in the third degree, holding that there was no error in the trial court's evidentiary rulings and that there was no reason to mandate Defendant's requested jury instruction.Defendant was convicted of strangulation in the second degree and assault in the third degree. The appellate court affirmed the convictions. The Supreme Court affirmed, holding (1) the appellate court did not err in upholding the trial court's decision to admit into evidence a written statement that Defendant made during a custodial interrogation; and (2) this Court declines Defendant's request to exercise its supervisory authority to require trial court, in cases in which the police fail to record an interrogation in violation of Conn. Gen. Stat. 54-lo(h), to instruct the jury that the police violated the law. View "State v. Christopher S." on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the decision of the appellate court affirming the judgment of the trial court convicting Defendant of three counts of sexual assault in the first degree and other crimes, holding that neither the structure nor the content of the prosecutor's closing argument deprived Defendant of his constitutional rights.On appeal, Defendant argued that the prosecutor deprived him of his constitutional rights to present a closing argument and to a fair trial by reserving her analysis of certain evidence for the rebuttal portion of closing argument and by mischaracterizing other evidence during rebuttal. The appellate court affirmed. The Supreme Court affirmed, holding that Defendant's claims of prosecutorial impropriety failed. View "State v. Gonzalez" on Justia Law

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The Supreme Court affirmed the judgment of the Appellate Court dismissing Petitioner's appeal from the trial court's denial of his request for leave to file a late petition for certification to appeal from the court's judgment denying his petition for a new trial, holding that the trial court did not abuse its discretion in concluding that certification to appeal should be denied.The trial court denied Petitioner's petition on the ground that Petitioner's claims were "meritless and too late." Petitioner appealed, claiming that the trial court improperly considered the merits of the petition rather than the reasons for the delay or other factors relevant to permitting a late filing. The Appellate Court dismissed Petitioner's appeal. The Supreme Court affirmed, holding that the trial court (1) abused its discretion by failing to engage in the proper analysis to determine whether to excuse the late petition for certification; and (2) did not abuse its discretion in determining that the petition failed to raise issues warranting certification. View "Mitchell v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the judgment of the appellate court, which affirmed the judgment of the habeas court denying Petitioner's amended petition for a writ of habeas corpus, holding that Petitioner failed to demonstrate that he was prejudiced by his trial counsel's failure to object to the prosecutor's improper comments during closing argument at Petitioner's criminal trial.Petitioner was convicted of murder. On appeal, the appellate court concluded that at least one of the prosecutor's comments during closing argument violated Petitioner's constitutional right to a fair trial but that Petitioner had not been prejudiced by the improper remarks. The Supreme Court affirmed, holding that the failure to Petitioner's criminal trial counsel to object to the prosecutor's improper remarks did not undermine the Court's confidence in the verdict. View "Ross v. Commissioner of Correction" on Justia Law

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The Supreme Court affirmed the judgment of the trial court revoking Defendant's probation and sentencing him to an effective term of imprisonment of two years, holding that the trial court did not err in denying Defendant's motion to dismiss the violation of probation charge.Defendant pleaded guilty to illegal possession of child pornography in the second degree. After Defendant was released on probation he was charged with violating his probation for failing to complete sex offender treatment. The trial court found that Defendant had violated his probation, revoked his probation, and sentenced him to a term of imprisonment of six years. Defendant appealed, arguing that the condition of probation on which the violation of probation charge was predicated violated his Fourteenth Amendment rights to due process and equal protection and the constitutional prohibition against the imposition of cruel and unusual punishment. The Supreme Court affirmed, holding that Defendant's claims of error lacked merit. View "State v. Imperiale" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the judgment of the appellate court affirming Defendant's conviction of sexually assaulting a twelve-year-old girl and sentencing him to a total effective prison term of thirty-three years, holding that there was no error.On appeal, Defendant argued that the trial court violated his due process right at sentencing by increasing his sentence because of his unwillingness to apologize to the victims. The appellate court affirmed, holding that the record did not support Defendant's contention. The Supreme Court affirmed, holding that the prison term imposed on Defendant did not give rise to an inference that the court punished him for refusing to issue an apology to the victims. View "State v. Angel M." on Justia Law

Posted in: Criminal Law