Justia Connecticut Supreme Court Opinion Summaries

Articles Posted in Criminal Law
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The Supreme Court affirmed the judgment of the trial court convicting Defendant of murder and carrying a pistol without a permit, holding that there was no error or abuse of discretion in the proceedings below.On appeal, Defendant argued that the trial court abused its discretion in excluding evidence of an assault of one of the state's witnesses and that the trial court erred by preventing him from impeaching another witness with evidence of previous criminal offenses. The Supreme Court affirmed, holding (1) the trial court's exclusion of evidence related to the assault did not violate Defendant's constitutional rights to present a defense and to confront the witnesses against him; and (2) the trial court did not violate Defendant's constitutional right to confrontation or the rules of evidence by preventing him from impeaching the witness with evidence of certain prior criminal convictions. View "State v. Torres" on Justia Law

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The Supreme Court reversed the judgment of the trial court reversing the decision of the Board of Firearms Permit Examiners ordering the issuance of a pistol permit to Defendant, holding that the Board did not abuse its discretion in finding that Defendant was suitable to obtain a pistol permit in Connecticut.While Conn. Gen. Stat. 29-28(b) prohibits the issuance of a permit to carry a pistol or revolver if the applicant has been convicted of a felony or certain enumerated offenses it contains no language prohibiting the issuance of a permit based on out-of-state, nonfelony convictions. Defendant in this case appealed the judgment of the trial court reading section 29-28(b)(2)(B) to include extraterritorial misdemeanor convictions. The Supreme Court reversed, holding that the trial court improperly substituted its judgment for the Board that Defendant was a suitable person to obtain a pistol permit. View "Stratford Police Department v. Board of Firearms Permit Examiners" on Justia Law

Posted in: Criminal Law
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The Supreme Court reversed the judgment of the appellate court affirming the decision of the habeas court dismissing Petitioner's petition for a writ of habeas corpus as barred by a procedural default, holding that Petitioner's pleadings met the standard necessary to survive a motion to dismiss.Petitioner was found guilty by a jury of sexual assault in the first degree and risk of injury to a child. In the instant case, Petitioner sought a second writ of habeas corpus, alleging that he suffered from severe intellectual disabilities and mental health afflictions at the time of trial and that he was denied due process because he was incompetent to be prosecuted and to stand trial. The habeas court dismissed the petition on the ground that Petitioner's due process claims were procedurally defaulted. The appellate court affirmed. The Supreme Court reversed, holding (1) Petitioner was not precluded from raising a freestanding competency claim; and (2) the habeas court erred in finding that Petitioner failed to allege sufficient prejudice to survive a motion to dismiss. View "Saunders 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 murder, holding that the appellate court did not err.On appeal, the appellate court concluded that the trial court had not abused its discretion in joining Defendant's case with the codefendant's case and that Defendant's right to confrontation was not violated when the trial court allowed a state's firearms examiner to testify about the findings of a second firearms examiner. The Supreme Court affirmed, holding (1) the appellate court did not err in determining that the trial court's joinder of Defendant's and his codefendant's cases was proper; (2) the admission of CSLI information into evidence was not error; and (3) the appellate court did not err by not determining that Defendant's right to confrontation was not violated by the challenged testimony, but the violation was harmless beyond a reasonable doubt. View "State v. Tyus" on Justia Law

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The Supreme Court affirmed the judgment of the habeas court denying in part Petitioner's petition for a writ of habeas corpus, holding that the habeas court correctly concluded that Petitioner did not demonstrate that he had suffered prejudice from the ineffective assistance of his trial counsel.Petitioner, a citizen of Jamaica who held a valid green card, pleaded guilty, pursuant to the Alford doctrine, to risk of injury to a child and strangulation in the third degree. The federal government subsequently initiated removal proceedings against Petitioner based, in part, on his conviction of risk of injury to a child. Petitioner filed a petition for a writ of habeas corpus, alleging ineffective assistance of counsel alleging that he would have gone to trial had his trial counsel not performed deficiently. The habeas court denied the petition as to the claim at issue in this appeal. The Supreme Court affirmed, holding that Petitioner did not meet his burden of establishing that there was a reasonable probability that he would have rejected the plea offer and proceeded to trial. View "Grant v. Commissioner of Correction" on Justia Law

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The Supreme Court affirmed the judgment of the trial court convicting Defendant of felony murder and other crimes, holding that there was no error or abuse of discretion in the proceedings below.Specifically, the Supreme Court held that the trial court (1) Defendant failed to establish under the third prong of State v. Golding, 567 A.2d 823 (Conn. 1989), that the trial court violated his federal due process rights by detaining three eyewitnesses to secure their attendance at trial; and (2) did not abuse its discretion by permitting the prosecutor to read passages from the witnesses' grand jury transcripts to the jury for substantive purposes pursuant to State v. Whelan, 513 A.2d 86 (Conn. 1986). View "State v. Gray" on Justia Law

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The Supreme Court reversed the judgment of the appellate court reversing the judgments of the trial court revoking Defendant's probation pursuant to Conn. Gen. Stat. 53a.32, holding that Defendant's conduct leading to the revocation was not entitled to First Amendment protection.After an escalated emotional confrontation with the staff of his child's preschool the trial court found that the State had met its burden of proving, by a preponderance of the evidence, that Defendant had violated the standard terms of his probation by violating Conn. Gen. Stat. 53a-181(a). On appeal, Defendant argued that his remarks warranted First Amendment protection because the State's evidence was insufficient to establish that his remarks constituted a true threat. The appellate court agreed and reversed. The Supreme Court reversed, holding that the appellate court erred in concluding that Defendant's remarks warranted First Amendment protection. View "State v. Taveras" on Justia Law

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The Supreme Court reversed in part the judgment of the appellate court reversing Defendant's convictions for intentional manslaughter, reckless manslaughter, and criminally negligent operation of a motor vehicle, holding that the appellate court improperly ordered a new trial on all three charges.At the sentencing hearing, the trial court vacated Defendant's intentional manslaughter conviction pursuant to State v. Polanco, 61 A.3d 1084 (Conn. 2013), and rendered judgment on the remaining counts of conviction. The appellate court concluded that Defendant's convictions for reckless manslaughter and criminally negligent operation were legally inconsistent but that neither reckless manslaughter nor criminal negligent operation was inconsistent with intentional manslaughter. The court then remanded the case for a new trial on all charges. The Supreme Court reversed in part, holding that the appellate court should have reinstated Defendant's intentional manslaughter conviction. View "State v. Daniels" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the judgment of the trial court convicting Defendant of sexual assault in the first and fourth degree, attempt to commit 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 argued (1) the trial court erred in overruling his objection brought pursuant to Batson v. Kentucky, 476 U.S. 79 (1986), objecting to the prosecutor's exercise of peremptory challenges to two prospective members of the jury; and (2) his conviction for risk of injury to a child violated constitutional double jeopardy protections. The Supreme Court affirmed, holding (1) the trial court did not commit clear error in determining that Defendant failed to meet his burden of proving by a preponderance of the evidence that the jury selection process in his case was tainted by purposeful discrimination; and (2) Defendant's conviction for two counts of risk of injury did not violate his right to be free from double jeopardy. View "State v. Jose A.B." on Justia Law

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The Supreme Court affirmed the judgment of the appellate court concluding that Defendant's confrontation rights were not violated by the admission into evidence of a codefendant's dual inculpatory statement to a fellow inmate acting at the behest of the state police, holding that there was no error.Defendant was convicted by a jury of murder, home invasion, burglary, and other crimes. The appellate court affirmed. At issue before the Supreme Court was whether the appellate court correctly concluded that the admission of the codefendant's dual inculpatory statement did not violate Defendant's confrontation rights under either the United States or Connecticut constitutions. The Supreme Court affirmed, holding that there was no error in the proceedings below. View "State v. Patel" on Justia Law