Justia Connecticut Supreme Court Opinion Summaries

The Supreme Court affirmed 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 legislature may and has remedied the constitutional violation in this case with parole eligibility.Defendant, a juvenile offender, was convicted of murder and other offenses. Defendant was originally sentenced to imprisonment for the functional equivalent of his lifetime without the possibility of parole. Subsequently, decisions by the United States and Connecticut Supreme Courts and enactments by the legislature resulted in changes to the sentencing scheme for juvenile offenders. As a result, Defendant will be parole eligible when he is about fifty years old. Defendant filed a motion to correct an illegal sentence based on Miller v. Alabama, 467 U.S. 460 (2012). The trial court ultimately dismissed the motion, concluding that Defendant's claim was moot in light of the United States Supreme Court's holding that Miller applied retroactively. The Supreme Court affirmed, holding (1) parole eligibility afforded by No. 15-84 of the 2015 Public Acts (P.A. 15-84) is an adequate remedy for a Miller violation under the Connecticut constitution; and (2) P.A. 15-84, 1 does not violate the separation of powers doctrine or Defendant's right to equal protection under the federal constitution. View "State v. McCleese" on Justia Law

The Supreme Court affirmed Defendant's conviction of murder and conspiracy to commit murder, holding that there was no error in the trial court's evidentiary rulings.On appeal, Defendant argued that the trial court erred in admitting testimony implicating him in the murder under the coconspirator exception to the hearsay rule and improperly admitted certain state of mind evidence. The Supreme Court disagreed, holding (1) even if the trial court incorrectly admitted the evidence under the coconspirator hearsay exception, the jury's verdict wasn't substantially affected by any such error; and (2) the trial court did not abuse its discretion in determining that the victim's state of mind was relevant as evidence of the deteriorating nature of his relationship with Defendant's gang from which the jury could reasonably infer Defendant's motive to kill him. View "State v. Ayala" on Justia Law

The Supreme Court affirmed the judgment of the appellate court upholding Defendant's convictions for several offenses stemming from the sexual assault of his minor daughter, holding that the evidence was sufficient to support Defendant's conviction for three counts of criminal violation of a restraining order and that the prosecutor did not commit misconduct.Specifically, the Court held (1) there was sufficient evidence from which the jury could conclude that Defendant had "knowledge of the terms of the order" because the court expressly instructed Defendant to limit contact with the children and Defendant heard Spanish language translations of the terms of the order; and (2) the prosecutor's comments and questions were not improper. View "State v. Elmer G." on Justia Law

The Supreme Court reversed the judgment of the Appellate Court concluding that Appellant's claim that his conviction violated the corpus delicti rule was unreviewable on appeal, holding that unpreserved corpus delicti claims are reviewable on appeal.Defendant was convicted of two counts of risk of injury to a child arising from two alleged incidents of sexual misconduct. Defendant appealed, arguing that the only evidence that he committed the second alleged act of misconduct were statements he made to the police and, therefore, that his second conviction violated the corpus delicti rule. Defendant, however, did not raise the corpus delicti issue or challenge the admissibility of his statements at trial. The Appellate Court dismissed the appeal, concluding that corpus delicti is an evidentiary rule that must be raised at trial to be reviewable on appeal. The Supreme Court reversed for the reasons set forth in a companion case decided today, State v. Leniart, __ A.3d __ (2019), holding that Defendant's corpus delicti claim was reviewable on appeal. View "State v. Robert H." on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the Appellate Court reversing Defendant's conviction for murder and three counts of capital felony and remanding the case for a new trial, holding that the Appellate Court erred in concluding that a videotape and expert testimony were improperly excluded during trial.Specifically, the Court held (1) Defendant's corpus delicti claim was reviewable on appeal because it was not merely evidentiary, but the Appellate Court properly concluded that there was sufficient evidence to support the conviction; (2) the Appellate Court erred in concluding that the trial court's erroneous exclusion of the videotape was not harmless; and (3) the Appellate Court erred in concluding that the trial court abused its discretion in precluding the expert testimony proffered by Defendant. View "State v. Leniart" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of murder and risk of injury to a child, holding that none of Defendant's claims of error warranted reversal of his convictions.Defendant was convicted of killing his seven-month-old son in an incident in which Defendant also attempted suicide. The Supreme Court affirmed, holding (1) the trial court did not err in denying Defendant's motion to suppress certain evidence arising from statements that Defendant had made to the police while in the hospital; (2) even assuming that the trial court improperly admitted Defendant's statements made at the hospital in violation of Conn. Gen. Stat. 54-lo because the interview was not recorded, any such error was harmless; and (3) the trial court did not err by precluding Defendant from introducing into evidence Defendant's offer to plead guilty to manslaughter in exchange for twenty-five years' incarceration. View "State v. Tony M." on Justia Law

The Supreme Court reversed in part the judgment of the Appellate Court concluding that Defendant failed to establish that his Sixth Amendment right to confront witnesses against him was violated at trial, holding that, under the specific circumstances of this case, Defendant established a violation of his right to confrontation.Defendant was found guilty of felony murder, manslaughter in the first degree with a firearm, and other offenses. At trial, the State introduced evidence that Defendant's DNA profile, which had been generated from a post arrest buccal swab, matched the DNA found on evidence from the crime scene. The State, however, did not call as a witness the analyst who processed the buccal swab and generated the DNA profile used in the comparison. On appeal, the Appellate Court concluded that Defendant's Sixth Amendment claim failed because the admission of DNA evidence did not violate Defendant's constitutional right to confrontation. The Supreme Court reversed, holding that the generation of DNA's profile was testimonial and that Defendant's Sixth Amendment right to confront witnesses against him was violated. View "State v. Walker" on Justia Law

The Supreme Court affirmed the judgment of the trial court denying Defendant's petition seeking erasure of an earlier finding that he had violated his probation, holding that the trial court properly rejected Defendant's argument that Conn. Gen. Stat. 54-142d compelled the erasure of a finding of a violation of probation that Defendant claimed was premised on the now decriminalized offense of possession of less than one-half ounce of marijuana.In State v. Menditto, 110 A.3d 410 (Conn. 2015), the Supreme Court held that Public Acts 2011, No. 11-71 "decriminalized" the possession of less than one-half ounce of marijuana for purposes of the erasure statute, section 54-142d. In his petition, Defendant argued that because his 2012 marijuana conviction had been erased from his record, no conviction any longer supported the violation of probation finding. The trial court rejected Defendant's argument. The Supreme Court affirmed, holding that section 54-142d did not entitle Defendant to erasure of the records pertaining to the 2012 finding that he violated his probation. View "State v. Dudley" on Justia Law

The Supreme Court affirmed the judgment of the Appellate Court dismissing Appellant's appeal from the judgment of the habeas court denying Appellant's amended petition for a writ of habeas corpus, holding that Appellant failed to meet his burden of showing that his criminal trial counsel rendered ineffective assistance by failing to present the testimony of a second alibi witness to support his defense.On appeal, Appellant claimed that the Appellate Court incorrectly concluded that the habeas court did not abuse its discretion in denying certification to appeal because he established that his counsel had performed deficiently. The Supreme Court disagreed, holding (1) it was not debatable among jurists of reason that Appellant rendered ineffective assistance; and (2) therefore, the Appellate Court correctly concluded that the habeas court did not abuse its discretion in denying Appellant's petition for certification to appeal. View "Meletrich v. Commissioner of Correction" on Justia Law

The Supreme Court affirmed the judgment of the trial court determining that Plaintiff's various statements and gestures regarding gun violence and mass shootings that led to his expulsion from the university were true threats that were not protected by the First Amendment to the United States Constitution, holding that Plaintiff's statements and gestures made on a public university campus were true threats.A university expelled Plaintiff from the university's campus after finding that Plaintiff's statements and actions with respect to gun violence had violated four provisions of the university's student code of conduct. Plaintiff brought this action alleging, among other things, that his expulsion violated his constitutional rights to due process and to freedom of speech. The trial court entered judgment in favor of Defendants. Plaintiff appealed, asserting that his statements and gestures were hyperbolic and humorous statements on a matter of public concern. The Supreme Court disagreed, holding that Plaintiff's statements and gestures were true threats that were not protected by the First Amendment. View "Haughwout v. Tordenti" on Justia Law