Justia Connecticut Supreme Court Opinion Summaries
Articles Posted in Criminal Law
State v. Michael T.
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
Posted in:
Constitutional Law, Criminal Law
State v. Francis
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
State v. Komisarjevsky
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
State v. Davis
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
State v. Armadore
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
State v. Jose R.
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
Francis v. Board of Pardons & Paroles
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
Moore v. Commissioner of Correction
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
State v. Christopher S.
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
State v. Gonzalez
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