Justia Connecticut Supreme Court Opinion Summaries

Articles Posted in Criminal Law
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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

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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

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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

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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

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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

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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

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The Supreme Court affirmed Defendant's conviction of murder, holding that there was no error or abuse of discretion in the proceedings below.At issue before the jury in this case was to decide whether to credit the testimony of two men, Eric Canty and Jules Kierce, who claimed to have been eyewitnesses to the murder committed years earlier of Isaiah Gantt, for which Defendant was convicted. Canty and Kierce were both incarcerated when they first contacted the state about the case, and both received consideration in return for testifying pursuant to cooperation agreements. The Supreme Court affirmed the judgment in its entirety, holding that the trial court (1) did not err in failing to give the jury a jailhouse informant instruction requested by defense counsel; (2) did not abuse its discretion in admitting the cooperation agreements of Canty and Kierce into evidence; and (3) did not abuse its discretion in refusing to allow cross-examination on the details of a prior arrest of Kierce. View "State v. Calhoun" on Justia Law

Posted in: Criminal Law
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The Supreme Court reversed the judgment of the appellate court reversing Defendant's conviction following her conditional plea of nolo contendere to the charge of possession of narcotics with intent to sell, holding that the appellate court incorrectly determined that the trial court erred by denying Defendant's motion to suppress.On appeal, Defendant argued that the trial court erred in denying her motion to suppress evidence seized by the police following a warrantless entry into her apartment on the grounds that the exigent circumstances and emergency aid doctrines supported the warrantless search of her apartment. The appellate court agreed and reversed. The Supreme Court reversed, holding (1) the warrantless entry was supported by the exigent circumstances doctrine; and (2) the evidence supported an objectively reasonable belief that someone inside Defendant's apartment was in need of emergency medical aid. View "State v. Curet" on Justia Law

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The Supreme Court affirmed the judgment of the appellate court upholding Defendant's conviction of violating Conn. Gen. Stat. 14-227a(a) and the enhancement of his sentence under Conn. Gen. Stat. 14-227a(g), holding that the appellate court correctly concluded that the trial court had properly sentenced Defendant as a third time offender under section 14-227a(g).At issue on appeal was whether the appellate court erred in concluding that the elements of Florida's driving under the influence statute, Fla. Stat. Ann. 316.193, which Defendant had twice been convicted of violating, were substantially the same as the elements of section 14-227a(a) for enhancement purposes under section 14-227a(g). The Supreme Court affirmed, holding that the essential elements of section 14-227a(a) and section 316.193 were substantially the same. View "State v. King" on Justia Law

Posted in: Criminal Law
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The Supreme Court reversed Defendant's conviction for two counts of aggravated sexual assault of a minor and two counts of risk of injury to a child, holding that the trial court improperly failed to order that certain material be turned over to the defense and that the error was not harmless beyond a reasonable doubt.On appeal, Defendant argued, among other things, that the trial court violated his Sixth Amendment right to confrontation by not ordering disclosure of the victims' psychiatric records to the defense. The Supreme Court agreed, holding that the trial court (1) committed harmful error by failing to order that exculpatory and relevant impeachment material contained in the victims' psychiatric records be turned over to the defense; (2) improperly precluded cross-examination of the mothers of the victims concerning their U visa applications; and (3) improperly instructed the jury. View "State v. Juan A. G.-P." on Justia Law