Justia Connecticut Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the Appellate Court dismissing Petitioner's appeal from the trial court's denial of his request for leave to file a late petition for certification to appeal from the court's judgment denying his petition for a new trial, holding that the trial court did not abuse its discretion in concluding that certification to appeal should be denied.The trial court denied Petitioner's petition on the ground that Petitioner's claims were "meritless and too late." Petitioner appealed, claiming that the trial court improperly considered the merits of the petition rather than the reasons for the delay or other factors relevant to permitting a late filing. The Appellate Court dismissed Petitioner's appeal. The Supreme Court affirmed, holding that the trial court (1) abused its discretion by failing to engage in the proper analysis to determine whether to excuse the late petition for certification; and (2) did not abuse its discretion in determining that the petition failed to raise issues warranting certification. View "Mitchell v. State" on Justia Law

The Supreme Court affirmed the judgment of the appellate court, which affirmed the judgment of the habeas court denying Petitioner's amended petition for a writ of habeas corpus, holding that Petitioner failed to demonstrate that he was prejudiced by his trial counsel's failure to object to the prosecutor's improper comments during closing argument at Petitioner's criminal trial.Petitioner was convicted of murder. On appeal, the appellate court concluded that at least one of the prosecutor's comments during closing argument violated Petitioner's constitutional right to a fair trial but that Petitioner had not been prejudiced by the improper remarks. The Supreme Court affirmed, holding that the failure to Petitioner's criminal trial counsel to object to the prosecutor's improper remarks did not undermine the Court's confidence in the verdict. View "Ross v. Commissioner of Correction" on Justia Law

The Supreme Court affirmed the judgment of the trial court revoking Defendant's probation and sentencing him to an effective term of imprisonment of two years, holding that the trial court did not err in denying Defendant's motion to dismiss the violation of probation charge.Defendant pleaded guilty to illegal possession of child pornography in the second degree. After Defendant was released on probation he was charged with violating his probation for failing to complete sex offender treatment. The trial court found that Defendant had violated his probation, revoked his probation, and sentenced him to a term of imprisonment of six years. Defendant appealed, arguing that the condition of probation on which the violation of probation charge was predicated violated his Fourteenth Amendment rights to due process and equal protection and the constitutional prohibition against the imposition of cruel and unusual punishment. The Supreme Court affirmed, holding that Defendant's claims of error lacked merit. View "State v. Imperiale" on Justia Law

The Supreme Court affirmed the judgment of the appellate court affirming Defendant's conviction of sexually assaulting a twelve-year-old girl and sentencing him to a total effective prison term of thirty-three years, holding that there was no error.On appeal, Defendant argued that the trial court violated his due process right at sentencing by increasing his sentence because of his unwillingness to apologize to the victims. The appellate court affirmed, holding that the record did not support Defendant's contention. The Supreme Court affirmed, holding that the prison term imposed on Defendant did not give rise to an inference that the court punished him for refusing to issue an apology to the victims. View "State v. Angel M." on Justia Law

The Supreme Court reversed the judgment of the appellate court reversing the judgment of the trial court convicting Defendant of burglary in the third degree, attempt to commit tampering with physical evidence, and attempt to commit arson in the second degree, holding that the appellate court improperly addressed an issue of evidentiary sufficiency sua sponte without calling for supplemental briefing.The appellate court reversed Defendant's conviction on the ground that there was insufficient evidence for the jury to have reasonably concluded that Defendant intended to tamper with physical evidence. The Supreme Court reversed, holding that the appellate court improperly decided an issue of evidentiary sufficiency sue sponte without ordering supplemental briefing, as required by Blumberg Associates Worldwide, Inc. v. Brown & Brown of Connecticut, Inc., 84 A.3d 840 (Conn. 2014). View "State v. Stephenson" on Justia Law

The Supreme Court reversed the judgment of the appellate court affirming Defendant's conviction of assault in the second degree, holding that the appellate court erred in determining that the trial court's investigative inadequacy jury instruction did not mislead the jury or otherwise deprive Defendant of his right to present an investigative inadequacy defense.The jury found Defendant guilty of assault in the second degree, and the court rendered judgment in accordance with the verdict. On appeal, Defendant argued that the jury instructions deprived him of his right to present a defense of investigative inadequacy. The appellate court rejected Defendant's claim and affirmed. The Supreme Court reversed, holding (1) the model jury instruction utilized by the trial court in this case failed properly to instruct the jury; and (2) the instructional error was not harmless. View "State v. Gomes" on Justia Law

The Supreme Court affirmed the judgment of the appellate court determining that Public Acts, Spec. Session, June 2015, No. 15-2, 1 (Spec. Sess. P.A. 15-2) does not apply retroactively, holding that the plain language of Spec. Sess. P.A. 15-2, 1 clearly and unambiguously prohibits retroactive application.Defendant was found guilty of one count of possession of less than four ounces of a cannabis-type substance and of two counts of possession of narcotics. Defendant filed a motion to correct an illegal sentence, which the trial court denied. The appellate court affirmed. Defendant appealed, arguing that a prospective-only application of the amendment would lead to an absurd or unworkable result and, alternatively, that the Supreme Court should adopt the amelioration doctrine. The Supreme Court affirmed and declined the invitation to adopt the amelioration doctrine, holding that the amendment does not apply retroactively and that this conclusion does not lead to an absurd or unworkable result. View "State v. Bischoff" on Justia Law

The Supreme Court reversed the judgment of the appellate court affirming the judgment of the trial court denying Defendant's motion to correct an illegal sentence, holding that the trial court lacked subject matter jurisdiction to entertain Defendant's motion because the motion sought only to modify Defendant's conviction, not his sentence.Defendant was convicted of felony murder and manslaughter. The trial court merged the conviction for manslaughter with the felony murder conviction for sentencing purposes. In his motion to correct an illegal sentence, Defendant argued that his sentence was illegal under the supervisory rule set forth in State v. Polanco, 61 A.3d 1084 (2013). The trial court concluded that Polanco did not apply retroactively and denied the motion. The appellate court affirmed. The Supreme Court reversed, holding that the trial court lacked jurisdiction to entertain Defendant's motion to correct an illegal sentence. View "State v. Smith" on Justia Law

The Supreme Court reversed the judgment of the appellate court affirming Defendant's conviction of assault in the second degree, holding that the appellate court erred in determining that a challenged jury instruction did not mislead the jury or otherwise deprive Defendant of his right to present an investigative inadequacy defense.At trial, Defendant's main defense was that the police had conducted an inadequate investigation of the incident leading to his conviction. On appeal, Defendant claimed that the jury instructions deprived him of his right to present his defense. The appellate court affirmed, holding that the trial court's jury instruction on investigative inadequacy was consistent with investigative inadequacy instructions approved by the Supreme Court. The Supreme Court reversed, holding that the model jury instruction utilized by the court in this case may have misled the jury or otherwise deprived Defendant of his right to present an investigative inadequacy defense. View "State v. Gomes" on Justia Law

The Supreme Court held that the legislature's action in amending Conn. Gen. Stat. 21a-279(a) to reclassify a first offense for possession of narcotics from a class D felony subject to a maximum sentence of imprisonment of seven years to a class A misdemeanor subject to a maximum sentence of one year of incarceration did not apply retroactively to criminal cases pending at the time the amendment became effective.Defendant was arrested and charged with violating section 21a-279(a) prior to the enactment of Spec. Public Acts, Sess. June 2015, No. 15-2, 1, which amended the statute. Defendant was convicted and sentenced after the amendment's enactment. On appeal, Defendant argued that the lower courts erred in determining that Spec. Sess. P.A. 15-2, 1 does not apply retroactively, and therefore, the sentence imposed on him was illegal. The Supreme Court affirmed, holding (1) the plain language of Spec. Sess. P.A. 15-2, 1 clearly and unambiguously prohibits retroactive application; and (2) this Court declines to adopt the amelioration doctrine. View "State v. Bischoff" on Justia Law