Justia Connecticut Supreme Court Opinion Summaries

The defendant was convicted of murder as an accessory and conspiracy to commit murder. She waived her right to a jury trial and opted for a trial by a three-judge panel. The defendant argued that the evidence was insufficient to support her conviction and that her waiver of a jury trial was not made knowingly, intelligently, and voluntarily because the canvassing court failed to explain that the three-judge panel did not need to be unanimous to convict. Additionally, she claimed that the panel improperly began deliberations before the close of evidence.The trial court found the defendant guilty based on evidence including her tumultuous relationship with the victim, her presence near the crime scene, and her inconsistent statements to the police. The defendant had initially claimed she was at home during the shooting but later admitted to being picked up by her cousin near the scene. Phone records also showed she contacted her cousin multiple times shortly before the murder.The Connecticut Supreme Court held that the evidence was sufficient to support the defendant’s conviction. The court noted that the defendant’s presence at the scene, her actions during the crime, and her inconsistent statements provided a reasonable basis for the panel’s verdict.However, the court invoked its supervisory authority to require that trial courts must specifically advise defendants who waive their right to a jury trial in favor of a three-judge panel that only two of the three judges need to agree to convict, unlike a jury which must be unanimous. The court concluded that this new rule should apply to the defendant’s case, reversed her conviction, and ordered a new trial.The court also addressed the defendant’s claim regarding premature deliberations by the panel, concluding that unlike juries, three-judge panels are not constitutionally prohibited from discussing the case before the close of evidence. View "State v. King" on Justia Law

The defendant was convicted of murder, carrying a pistol without a permit, and criminal possession of a firearm. The case involved the shooting of the victim, Giovanni Rodriguez, in a hotel parking lot. The defendant, Trevor Monroe Outlaw, was identified as the shooter by his girlfriend, Cheenisa Rivera, who testified against him under a cooperation agreement. Rivera and another witness, Loretta Martin, were both in witness protection and testified that the defendant was in the car from which the shots were fired.The trial court denied the defendant's motion to preclude evidence of Rivera's plea agreement, which included her guilty plea to conspiracy to commit murder. The jury found the defendant guilty of murder and carrying a pistol without a permit, and the court found him guilty of criminal possession of a firearm. The defendant appealed, arguing that the trial court erred by not questioning or dismissing a juror who appeared to be sleeping, improperly admitted evidence related to witness protection, allowed Rivera to testify about her guilty plea, and that the prosecutor's comments during closing arguments violated his right to a jury trial.The Connecticut Supreme Court held that the trial court's limited inquiry into the allegedly sleeping juror was adequate and did not deprive the defendant of a fair trial. The court also found that although the trial court improperly admitted evidence related to witness protection, the defendant did not demonstrate that this resulted in a manifest injustice. The admission of Rivera's guilty plea was deemed harmless, as it did not substantially impact the jury's verdict. Finally, the court concluded that the prosecutor's remarks during closing arguments did not violate the defendant's right to a jury trial, as they were intended to bolster Rivera's credibility rather than criticize the defendant's decision to go to trial. The judgment of the trial court was affirmed. View "State v. Outlaw" on Justia Law

The defendant was convicted of assault in the first degree after an altercation with a friend, during which he stabbed the friend multiple times. Following the incident, the defendant sought medical treatment at a hospital for injuries sustained during the fight. While at the hospital, he was questioned by several police officers without being advised of his Miranda rights. The defendant moved to suppress the statements made during these interactions, arguing that he was in custody and subject to interrogation without proper Miranda warnings.The trial court denied the motion to suppress, finding that the defendant was not in custody during the hospital questioning. The court noted that the defendant was not handcuffed, was coherent despite his intoxication, and was not subjected to prolonged or aggressive questioning. The defendant was subsequently found guilty of assault in the first degree and sentenced to ten years of incarceration, suspended after seven years, with five years of probation.The Appellate Court reversed the conviction, concluding that the defendant was in custody for Miranda purposes when questioned by the police at the hospital. The court reasoned that the presence of multiple officers, the defendant's physical condition, and the nature of the questioning created a custodial environment. The Appellate Court held that the trial court should have suppressed the statements and remanded the case for a new trial.The Connecticut Supreme Court reviewed the case and reversed the Appellate Court's decision. The Supreme Court held that the defendant was not in custody during the hospital interactions. The court emphasized that the defendant was not physically restrained by the police, the questioning was not aggressive or prolonged, and the defendant was informed that he was free to leave for police purposes. The court concluded that a reasonable person in the defendant's position would not have felt a restraint on freedom of movement to the degree associated with a formal arrest. Therefore, the police were not required to administer Miranda warnings, and the trial court's denial of the motion to suppress was affirmed. View "State v. Garrison" on Justia Law

The defendant was convicted of assaulting public safety personnel and interfering with an officer after injuring a police officer during the execution of an arrest warrant. The warrant included charges of assault in the first degree and criminal possession of a firearm. The officers, part of a multi-agency task force, used significant force to enter the defendant's residence, where the defendant resisted arrest, leading to the officer's injuries.The trial court admitted testimony about the felony charges in the arrest warrant and identified the task force as the "Violent Fugitive Task Force." The defendant objected, arguing that this evidence was unduly prejudicial. The trial court overruled the objections, finding the evidence relevant to explain the officers' conduct and the reasonableness of their use of force. The jury found the defendant guilty, and the trial court sentenced him to eight years of incarceration followed by two years of special parole.The Appellate Court affirmed the trial court's decision, concluding that the evidence was relevant to show the officers were acting in the performance of their duties and that any prejudice was mitigated by limiting instructions. The defendant appealed to the Connecticut Supreme Court, arguing that the evidence was unduly prejudicial.The Connecticut Supreme Court held that the trial court did not abuse its discretion in admitting the names of the felony charges, as they were relevant to the officers' use of force and the performance of their duties. However, the Court found that the name "Violent Fugitive Task Force" had no probative value and was unfairly prejudicial. Despite this, the Court concluded that the error was harmless given the strength of the state's case and the defense's focus on causation rather than the officers' conduct. The judgment of the Appellate Court was affirmed. View "State v. Delacruz-Gomez" on Justia Law

The defendant was convicted of home invasion and first-degree burglary after breaking into an apartment while armed with a Crosman Vigilante air gun. The air gun was loaded with pellets but lacked a CO2 cartridge, and the chamber for the cartridge was sealed with duct tape. The defendant was identified by one of the residents after a physical altercation and was later arrested. The state needed to prove that the defendant was armed with a "deadly weapon or dangerous instrument" to secure a conviction.The Superior Court in the judicial district of Danbury denied the defendant's motion for a judgment of acquittal, which argued that the air gun was not operable and thus not a deadly weapon. The jury was instructed that a deadly weapon is any weapon from which a shot may be discharged, whether loaded or unloaded, and found the defendant guilty of home invasion and first-degree burglary. The trial court rendered judgment consistent with the verdict and sentenced the defendant to sixteen years of incarceration, suspended after twelve years, and five years of probation.The Connecticut Supreme Court reviewed the case and determined that the question of whether the air gun was a deadly weapon was subject to plenary review. The court concluded that the air gun, which required significant effort to be made operable due to the duct tape sealing the CO2 chamber, was not a weapon from which a shot could be readily discharged. The court held that the trial court's instruction to the jury was legally erroneous, as it did not convey the immediacy requirement implied by the statute defining a deadly weapon. Consequently, the defendant's conviction could not stand, and the judgment was reversed, with the case remanded for a new trial. View "State v. Carter" on Justia Law

In September 1995, the body of a young woman, later identified as the defendant's daughter, was found in New Britain, Connecticut. The body was wrapped in trash bags and sleeping bags, and the police collected hairs and palm prints from the scene. Around the same time, the defendant told a family member he was leaving the country for a job and that his wife and daughter had already left. In October 1995, the body of the defendant's wife was found in Massachusetts. Both were reported missing later that year. In 2014, law enforcement collected DNA and prints from the defendant, linking him to the crime scene. The defendant was convicted of his wife's murder in Massachusetts and later charged with his daughter's murder in Connecticut.The trial court denied the defendant's motion to dismiss for lack of territorial jurisdiction, applying a presumption that the murder occurred where the body was found. The court also denied the defendant's request for a jury instruction that his palm prints on the trash bags could not establish his connection to the crime unless they were impressed at the time of the crime. The jury found the defendant guilty, and he was sentenced to sixty years in prison.The Connecticut Supreme Court affirmed the trial court's decision. The court held that the presumption that a murder occurred where the body was found was valid and did not violate due process. The court also found sufficient evidence to establish the defendant's identity as the murderer, including consciousness of guilt evidence and physical evidence linking him to the crime scene. The court further held that the trial court properly declined to provide the requested jury instruction on fingerprint evidence, as the palm prints were not the only or principal evidence against the defendant. View "State v. Honsch" on Justia Law

In 1990, the petitioner was convicted of murder, largely based on two cross-racial eyewitness identifications. Both witnesses initially identified another person as the shooter but later identified the petitioner, who was the only Black man at the defense table during a probable cause hearing. The petitioner challenged the identification procedures and jury instructions on appeal, but the Connecticut Supreme Court upheld his conviction.The petitioner filed a habeas petition in 2016, claiming that the admission of unduly suggestive and unreliable eyewitness identification evidence violated his due process rights. He also argued that advances in the science of eyewitness identification since his conviction called into question the validity of his conviction. The habeas court dismissed these claims, concluding they were barred by res judicata and that the decisions in State v. Guilbert and State v. Dickson did not apply retroactively. The court also dismissed and denied other claims of ineffective assistance of counsel.The Connecticut Supreme Court reviewed the case and concluded that the principles set forth in Dickson, which addressed the suggestiveness of first-time, in-court identifications, must apply retroactively on collateral review. The court reasoned that the rule in Dickson was a result of scientific developments that significantly improve the accuracy of convictions and that the petitioner had raised similar claims in his direct appeal. The court reversed the Appellate Court's decision and remanded the case for a trial on the petitioner's due process and actual innocence claims, directing the lower court to apply the holding of Dickson retroactively. View "Tatum v. Commissioner of Correction" on Justia Law

The defendant, Tyhitt Bember, was convicted of felony murder, attempt to commit robbery in the first degree, and carrying a pistol or revolver without a permit in connection with the shooting death of a victim. The defendant, armed with a revolver, had instructed a companion to follow the victim in a car. After confronting the victim on foot, the defendant decided to rob him. When the victim resisted, the defendant shot him five times. The state's case rested almost entirely on the testimony of two witnesses who were facing charges for their involvement in another homicide and had entered into cooperation agreements with the state. The defendant had allegedly confessed his involvement in the victim’s murder to one of these witnesses.The defense moved to preclude the state from introducing the cooperation agreements during its direct examination of the witnesses. The trial court granted the motion but ruled that the prosecutor would be permitted to use leading questions to flesh out the terms of the agreements. The defense also moved for a pretrial hearing regarding the reliability of the witnesses’ proposed trial testimony. Following a hearing, the trial court found that the witnesses’ proposed trial testimony was sufficiently reliable to be admitted at trial.The defendant appealed, arguing that the trial court had abused its discretion in permitting the prosecutor to question the witnesses during direct examination regarding the specific terms of their cooperation agreements with the state. The defendant also claimed that the prosecutor had impermissibly vouched for the witnesses’ credibility by introducing the truthfulness provisions of their cooperation agreements, eliciting testimony from the witnesses that their attorneys were present in the courtroom, and referencing their prior testimony in other criminal cases on behalf of the state. The defendant further claimed that the trial court had abused its discretion in concluding that the witnesses’ testimony was reliable and admissible.The Supreme Court of Connecticut affirmed the trial court's decision. The court held that the defendant had waived his claim regarding the prosecutor's questioning of the witnesses about their cooperation agreements. The court also held that the prosecutor's introduction of the truthfulness provisions of the witnesses' cooperation agreements did not constitute improper vouching. The court further held that the trial court did not abuse its discretion in determining that the witnesses' proposed trial testimony was sufficiently reliable to be admissible at trial. View "State v. Bember" on Justia Law

A man convicted of sexual assault and risk of injury to a child appealed his conviction, arguing that he was entitled to access the content of handwritten journals authored by the complainant. The complainant had revealed the existence of these journals during the trial, stating that they were created as part of her therapy following the abuse and contained details about her relationship with the defendant and the abuse he had inflicted. The defendant claimed that these journals constituted a "statement" under relevant rules of practice and that his rights were violated as the prosecutors did not personally review the journals for exculpatory information.The Appellate Court affirmed the conviction, concluding that the defendant had waived his claim to the journals and that the prosecutors were not constitutionally required to personally review the journals. The defendant appealed to the Supreme Court of Connecticut, which agreed with the state's alternative argument that the journals were not subject to disclosure because they did not constitute a statement that was adopted or approved by the complainant. The court also concluded that the Brady review of the journals by a nonlawyer member of the state’s attorney’s office was constitutionally adequate. Therefore, the court affirmed the judgment of the Appellate Court. View "State v. C." on Justia Law

The case revolves around a plaintiff who was arrested for operating a motor vehicle while under the influence of intoxicating liquor. The arresting officer prepared a report of the incident and mailed it to the Department of Motor Vehicles (DMV), but not within the three business days required by statute. At the plaintiff's license suspension hearing, the plaintiff's attorney objected to the admission of the report on the grounds that it was not prepared and mailed within the statutory timeframe. The hearing officer overruled the objection and admitted the report, which was the only evidence submitted at the hearing.The trial court dismissed the plaintiff's appeal, concluding that strict adherence to the preparation and mailing requirement was not necessary for the report to be admissible. The Appellate Court affirmed the trial court's judgment, concluding that the preparation and mailing requirement is directory, and therefore, strict compliance with that requirement is not necessary for a report to be admissible at a license suspension hearing.The Supreme Court of Connecticut reversed the Appellate Court's judgment. The court held that the hearing officer abused her discretion in admitting an incident report that did not strictly comply with the preparation and mailing provision of the statute in the absence of testimony from the arresting officer. The court concluded that the preparation and mailing requirement was mandatory because it promoted the accuracy and reliability of the information that would be used at a license suspension hearing. The court clarified that the statute describes substantive requirements that incident reports must meet, and the failure to meet those requirements renders a report inadmissible insofar as it fails to satisfy the exception for the report to be admitted without the need to produce the arresting officer at the suspension hearing. View "Marshall v. Commissioner of Motor Vehicles" on Justia Law