Justia Connecticut Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the appellate court affirming Defendant's conviction of risk of injury to a child, holding that Defendant was not entitled to relief on his allegations of error.On appeal, Defendant argued, among other things, that the trial court abused its discretion in precluding defense counsel from asking potential jurors about their views on parents kissing their children on their lips. The Supreme Court affirmed, holding (1) even if the trial court improperly limited defense counsel's questions to potential jurors, any error did not result in harmful prejudice; and (2) the trial court did not abuse its discretion by admitting into evidence a video recording of a forensic interview of the victim concerning the crimes at issue. View "State v. James K." on Justia Law

The Supreme Court reversed the judgment of the habeas court granting Petitioner's petition for a writ of habeas corpus, holding that the habeas court erred when it determined that trial counsel for Petitioner rendered deficient performance under Strickland v. Washington, 466 U.S. 668 (1984).Petitioner was convicted of murder and sentenced to sixty-years' imprisonment. Petitioner later brought his habeas petition, claiming ineffective assistance of trial counsel. The habeas court determined that trial counsel rendered ineffective assistance by failing to recommend that Petitioner accept the court's pretrial offer of a forty-five-year sentence of incarceration. The Supreme Court reversed, holding that, under the circumstances of this case, counsel's representation of Petitioner did not amount to ineffective representation. View "Maia v. Commissioner of Correction" on Justia Law

The Supreme Court reversed the judgment of the appellate court dismissing Petitioner's appeal, holding that unpreserved claims challenging the habeas court's handling of the habeas proceeding are reviewable under the plain error doctrine and State v. Golding, 567 A.2d 832 (Conn. 1989), if the petition can demonstrate that the unpreserved claims meet the criteria set forth in Simms v. Warden, 646 A.2d 126 (Conn. 1994)(Simms II).Petitioner was convicted of robbery in the first degree and sentenced to twelve years' imprisonment. Petitioner later filed a petition for writ of habeas corpus challenging his conviction. The habeas court dismissed the petition after a hearing, concluding that there was no good cause to proceed because Petitioner filed outside of the applicable time limits. The appellate court dismissed Petitioner's appeal, concluding that the certification requirement in Conn. Gen. Stat. 52-470(g) barred appellate review of unpreserved claims in uncertified appeals under Golding and the plain error doctrine. The Supreme Court dismissed the appeal and remanded for further considerations, holding that plain error and Golding review is available to challenge the habeas court's handling of the habeas proceeding despite denying a petition for certification to appeal if the appellant can demonstrate that the unpreserved claims meet the criteria set forth under Simms II. View "Banks v. Commissioner of Correction" on Justia Law

The Supreme Court affirmed the judgment of the appellate court affirming Defendant's conviction for the sale of a narcotic substance in violation of Conn. Gen. Stat. 21a-277(a), holding that Defendant was not entitled to relief on his allegations of error.On appeal to the appellate court, Defendant argued, as relevant to this appeal, that the trial court erred in imposing a discovery sanction precluding the admission of a written memorandum containing the inconsistent statement of a key state witness and in permitting the prosecutor to elicit expert opinion testimony on cross-examination of defense counsel's private investigator. The appellate court affirmed, holding (1) the discovery sanction was improper, but the error was harmless; and (2) even if the cross-examination at issue was improper, it was harmless. The Supreme Court affirmed, holding that the appellate court properly found that any error was harmless. View "State v. Massaro" on Justia Law

The Supreme Court affirmed the judgment of the appellate court affirming Defendant's conviction of burglary in the second degree, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Court held (1) Defendant's constitutional rights to confrontation, to present a defense, and to a fair trial under the Sixth and Fourteenth Amendments to the federal constitution were not violated during the underlying proceedings; and (2) assuming, without deciding, that the trial court abused its discretion when it limited defense counsel's cross-examination of the victim on the ground that the proffered line of questioning was speculative, Defendant failed to satisfy his burden of proving harm. View "State v. Lanier" on Justia Law

The Supreme Court held that absolute immunity attaches to statements made in judicial or quasi-judicial proceedings and that while Jane Doe was not entitled to absolute immunity, a qualified privilege is appropriate for alleged victims of sexual assault presented in the context of this case.In disciplinary proceedings conducted at Yale University by the University-Wide Committee on Sexual Misconduct (UWC) Doe accused Plaintiff of sexual assault, resulting in Plaintiff's expulsion from Yale and criminal charges being brought against him. Plaintiff was acquitted. At issue in this appeal was whether Doe, who enjoyed absolute immunity in a subsequent civil action challenging her testimony given during Plaintiff's criminal proceeding, should likewise be afforded absolute immunity from suit for her statements made during the UWC proceeding. The Supreme Court held (1) absolute immunity attaches to statements in judicial or quasi-judicial proceedings; (2) the USC's proceeding did not meet the conditions necessary to be considered quasi-judicial, and therefore, Doe was not entitled to absolute immunity; but (3) due to the public interest in encouraging the proper reporting of sexual assaults a qualified privilege is appropriate for alleged victims of sexual assault at institutions of higher education. View "Khan v. Yale University" on Justia Law

The Supreme Court affirmed the judgment of the trial court denying Defendant's motion to correct an illegal sentence, holding that a trial court can properly consider conduct related to a charge of which a criminal defendant was acquitted when the court sentences the defendant on other charges of which the defendant was convicted but that courts should be extremely cautious in relying on such conduct in sentencing.Defendant was convicted and sentenced for robbery in the first degree and other offenses. Defendant later filed his motion to correct an illegal sentence arguing that the sentencing court violated his constitutional rights by considering conduct underlying a charge for which he was acquitted - assault. The trial court denied the motion. The Supreme Court affirmed, holding (1) a sentencing judge may consider a broad range of conduct so long as the sentence falls within the statutory range and the conduct does not serve as grounds to enhance the sentence; and (2) the sentencing court in this case did not violate Defendant's right to trial by jury under the Sixth Amendment or his right to due process under the Fourteenth Amendment by considering the conduct underlying his assault charge. View "State v. Langston" on Justia Law

The Supreme Court dismissed this interlocutory appeal in which Defendant argued that the trial court erred in denying his motion to dismiss because the State intentionally had delayed the prosecution in violation of his right to a speedy trial, holding that the denial of Defendant's motion to dismiss did not constitute a final judgment.Defendant filed a motion to dismiss criminal charges the State had reinstitute against him after the trial accepted a nolle prosequi on the ground that the State was unable to locate material witnesses, arguing that the State had violated his right to a speedy trial by intentionally delaying the prosecution, and consequently, he lost the ability to have the counsel of his choice represent him at trial. The trial court denied the motion, and Defendant appealed. The Supreme Court dismissed the appeal for lack of jurisdiction, holding that Defendant failed to satisfy either prong of the test established in State v. Curcio, 463 A.2d 566 (Conn. 1983). View "State v. Malone" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of employing a minor in an obscene performance in violation of Conn. Gen. Stat. 53a-196a, sexual assault in the first degree, and other offenses, holding that Defendant was not entitled to relief on his claims of error.Specifically, the Supreme Court held (1) the trial court did not abuse its discretion in denying Defendant's motion to sever the sexual offenses with the nonsexual offenses and in joining the informations for trial; (2) the obscene performance statute was not unconstitutionally vague as applied to Defendant's conduct, and the First Amendment did not require the Court to undertake an independent appellate review of that conviction; (3) the trial court's potentially incorrect rulings, including those relating to the excludion from evidence video recordings of forensic interviews of the victim, were harmless error beyond a reasonable doubt; and (4) the evidence was sufficient to support Defendant's convictions of assault in the third degree, criminal violation of a protective order, and stalking in the first degree. View "State v. Michael R." on Justia Law

The Supreme Court answered a certified question of law concerning the applicability of Conn. Gen. Stat. 53-37 to this case, concluding that section 53-37 did not apply because Plaintiff's complaint did not allege any speech constituting an "advertisement."Plaintiff brought this reenforcement action challenging 53-37, which provides that "[a]ny person who, by his advertisement, ridicules or holds up to contempt any person or class of persons, on account of the creed, religion, color, denomination, nationality or race of such person or class of persons, shall be guilty of a class D misdemeanor." Plaintiff alleged that the statue violated his right to free speech under the First and Fourteenth Amendments to the United States Constitution and sought declaratory and injunctive relief seeking permanently to enjoin the enforcement of the statute. Defendants filed a motion to dismiss for lack of subject matter jurisdiction, arguing that Plaintiff lacked standing to bring the action because he had failed to allege an injury in fact. The Supreme Court answered a certified question regarding the issue by answering that the uncontroverted evidence demonstrated that section 53-37 was not intended to encompass the type of personal, noncommercial speech alleged in Plaintiff's complaint. View "Cerame v. Lamont" on Justia Law