Justia Connecticut Supreme Court Opinion Summaries

The case involves a defendant who was convicted, after a jury trial, of burglary in the first degree, criminal mischief in the first degree, and threatening in the second degree, among other crimes. The defendant had unlawfully entered his brother's residence and caused significant damage within it. Upon appeal, the defendant argued that the trial court had committed plain error by not identifying the specific crime or crimes he allegedly intended to commit when he entered the residence during the jury instruction on first-degree burglary.However, the Supreme Court of Connecticut held that the Appellate Court correctly concluded that the trial court had not committed plain error. The trial court's instruction accurately recited the elements of the burglary charge and clarified that the intent to commit a crime within the building is a distinct element. Furthermore, the court noted that although it is the better practice for trial courts to name the crime or crimes and define such elements in its instructions, it has never been clearly held to be mandatory.Additionally, the court found that even if there was a patent error in the court’s instruction, the omission did not result in a manifest injustice. The evidence presented at trial established that the defendant had violently forced his way into the residence and caused extensive damage, which satisfied the intent element. View "State v. Kyle A." on Justia Law

In the State of Connecticut, the petitioner, who was convicted of felony murder and other crimes, filed a petition for a writ of habeas corpus in 2018, more than five years after his conviction was deemed final. The petitioner initially filed a timely habeas petition in 2012 but withdrew it due to dissatisfaction with his assigned counsel. When filing his 2018 habeas petition, the Commissioner of Correction moved for an order to show cause why the petition should not be dismissed as untimely under § 52-470 (c) and (e). The petitioner argued that good cause existed to excuse the untimely filing since his previous counsel had failed to inform him of the deadline to refile his petition. The habeas court dismissed the 2018 petition as untimely, a decision upheld by the Appellate Court.On appeal to the Supreme Court of Connecticut, the Court reversed the judgment of the Appellate Court, concluding that the habeas court’s determination that no good cause existed was based on a clearly erroneous factual finding. The Court found that the habeas court wrongly assumed that the petitioner's previous counsel had advised him to refile his habeas petition immediately after withdrawing the first one. The Court also clarified that, under the totality of the circumstances, ineffective assistance of counsel can be considered an external, objective factor that could establish good cause to excuse the late filing of a habeas petition under § 52-470 (c) and (e). The case was remanded for a new hearing and a good cause determination under § 52-470 (c) and (e) in light of its factual findings with respect to the performance of prior habeas counsel. View "Rose v. Commissioner of Correction" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of one count of sexual assault in the first degree and two counts of risk of injury to a child, holding that Defendant was not entitled to relief on his claims of error.On appeal, Defendant argued that the State infringed on his right to due process by providing an inadequate notice of intent to offer evidence of other sexual misconduct and that the trial court abused its discretion by admitting the testimony of his daughter concerning sexual misconduct he had engaged in with her fourteen years earlier. The Supreme Court affirmed, holding (1) Defendant had no constitutional right to pretrial notice of other sexual misconduct evidence; and (2) the trial court did not abuse its discretion by admitting evidence of Defendant's other sexual misconduct with his daughter. View "State v. Samuel U." on Justia Law

The Supreme Court affirmed the judgment of the appellate court concluding that the trial court lost jurisdiction when it dismissed Defendant's pending criminal charges and, therefore, was without jurisdiction to entertain the State's motion to open the judgment and reinstate the charges, holding that criminal courts do not have jurisdiction to open a judgment following a dismissal.After Defendant was charged with risk of injury to a child and breach of the peace in the second degree the court granted his application to participate in a supervised diversionary program for individuals with psychiatric disabilities. The trial court later dismissed the charges against him. The State moved to open the judgment of dismissal on the grounds that Defendant failed to satisfactorily complete the diversionary program. The trial court granted the motion on the grounds that the dismissal was erroneous. The appellate court reversed, concluding that the trial court lost jurisdiction over the matter when it rendered the judgment of dismissal. The Supreme Court affirmed, holding that the appellate court properly concluded that the trial court lacked jurisdiction to entertain the State's motion to open the judgment and reinstate the charges. View "State v. Butler" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the trial court finding Defendant guilty of manslaughter in the first degree, criminal possession of a firearm, and possession of a weapon in a motor vehicle, holding that the evidence was insufficient to support Defendant's conviction of possessing a weapon in a motor vehicle.Specifically, the Supreme Court held (1) any claimed error on the part of the trial court in violating Defendant's right to confront the witnesses against him under the Sixth Amendment by allowing the chief medical examiner to testify about the results of the victim's autopsy, which the chief medical examiner had not performed himself, was harmless; and (2) the evidence was insufficient to support Defendant's conviction of possessing a weapon in a vehicle in violation of Conn. Gen. Stat. 29-38(a). View "State v. Robles" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of one count of sexual assault in the first degree and two counts of risk of injury to a child, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Court held (1) the trial court did not err in admitting certain testimony pursuant to the constancy of accusation doctrine; (2) the trial court did not err in excluding impeachment evidence of pending criminal charges against the State's key witness; and (3) the first degree of sexual assault charge was not ambiguous and therefore did not violate Defendant's right to jury unanimity under the Sixth Amendment. View "State v. Velasquez-Mattos" on Justia Law

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