Justia Connecticut Supreme Court Opinion Summaries

The Supreme Court reversed the order of the trial court requiring Defendant to submit both to an examination for sexually transmitted diseases pursuant to Conn. Gen. Stat. 54-102a(a) and to testing for human immunodeficiency virus (HIV) pursuant to section 54-102a(b), holding that the trial court erred.Defendant was charged with patronizing a prostitute who was the victim of human trafficking and conspiracy to commit trafficking in persons. The State subsequently filed a motion seeking a court order requiring Defendant to submit to the examination and testing at issue. Thereafter, several victims of Defendant's alleged misconduct filed similar motions. The trial court ordered Defendant to submit to the examination and testing. Defendant appealed. The Supreme Court reversed, holding (1) under Conn. Const. art. I, 7, the trial court must make a finding that either an examination pursuant to section 54-102a(a) or testing pursuant to section 54-102a(b), or both, would provide would provide useful, practical information; and (2) because the trial court did not apply this standard, the case must be remanded for a new hearing. View "State v. Bemer" on Justia Law

The Supreme Court affirmed the judgment of the appellate court affirming Defendant's convictions of three distinct crimes in connection with his attack on a single victim over the course of an eight-hour period on a single day, holding that there was no error.Defendant was convicted of assault in the third degree, unlawful restraint in the first degree, and strangulation in the second degree. On appeal, Defendant argued that his constitutional right to a jury trial was violated when the trial court, rather than the jury, determined that the charges of assault and unlawful restraint were not "upon the same incident" as that giving rise to the charge of strangulation. The appellate court affirmed. The Supreme Court affirmed, holding that the trial court's determination at sentencing that the offenses of strangulation, assault, and unlawful restraint were not "upon the same incident" did not implicate the constitutional principles underlying Apprendi v. New Jersey, 530 U.S. 490 (2000), or double jeopardy concerns. View "State v. Watson" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the trial court convicting Defendant of one count of intentional assault and one count of reckless assault, holding that the appellate court correctly concluded that the jury's verdicts of guilty of intentional assault and reckless assault were not legally erroneous.On appeal, Defendant argued that the verdicts finding him guilty of intentional assault and reckless assault were legally inconsistent because their requisite mental states of intentional and reckless were mutually exclusive. The appellate court concluded that the convictions were consistent because each mental state pertains to a different result. The Supreme Court affirmed, holding that the jury reasonably could have found that Defendant intended to cause the victim serious physical injury and simultaneously disregarded the risk that his conduct would cause the victim's death. View "State v. Alicea" on Justia Law

The Supreme Court affirmed Defendant's conviction of two counts of sexual assault in the first degree and two counts of risk of injury to a child, holding that there was no error in the proceedings below.On appeal, Defendant asserted that the trial court erred in admitting evidence of the victim's out-of-court demeanor and that the prosecutor made improper remarks during rebuttal and closing argument. The Supreme Court affirmed, holding (1) the allegedly improper admission of the victim's demeanor testimony was harmless; and (2) two of the prosecutor's remarks made during closing argument and rebuttal were improper, but these improprieties did not deprive Defendant of a fair trial. View "State v. Courtney G." on Justia Law

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

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

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

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

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

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