Justia Connecticut Supreme Court Opinion Summaries

The State charged Defendant with murder and manslaughter in the first degree with a firearm. The jury rendered verdicts of guilty on both charges. Defendant filed a motion for judgment of acquittal and for a new trial, arguing that the verdicts were legally inconsistent. The trial court denied the motion, concluding (1) Defendant had waived the claim by failing to request a jury instruction that he could not be convicted of both charges; but (2) the verdict of guilty on the manslaughter charge must be vacated pursuant to case law because when a defendant is convicted of both a greater offense and a lesser included offense, the property remedy is to vacate the conviction on the lesser included offense. The Supreme Court vacated both guilty verdicts, holding (1) legally inconsistent verdicts involve jury error that may be raised for the first time after the verdicts have been returned or on appeal, and therefore, the trial court erred in determining that Defendant had waived his claims that the guilty verdicts were legally inconsistent; and (2) the verdicts were legally inconsistent, and neither verdict can stand. Remanded for a new trial. View "State v. Chyung" on Justia Law

After a jury trial, Defendant was convicted of home invasion, robbery in the first degree, larceny in the second degree, and assault of an elderly person in the third degree. The Supreme Court affirmed, holding (1) the trial court did not err in denying Defendant’s motion to suppress certain statements he made to police because Defendant was not in custody when he made the statements; (2) the trial court improperly allowed a police officer to present certain testimony regarding cell phone records and maps, but the error was harmless; and (3) the evidence was sufficient to support the convictions. View "State v. Edwards" on Justia Law

Defendant was convicted of interfering with an officer, criminal trespass, and disorderly conduct. The conviction stemmed from an incident at Saint Francis Hospital and Medical Center in Hartford. Defendant appealed, arguing that the trial judge abused his discretion in denying Defendant’s motion for disqualification following the judge’s disclosure that he had previously been employed by the hospital. The Supreme Court affirmed, holding (1) Defendant’s claim was amenable to review; and (2) Defendant failed to meet his burden of establishing the factual basis that created an appearance of bias or partiality, and therefore, the judge properly denied Defendant’s motion for disqualification. View "State v. Milner" on Justia Law

After a jury trial, Defendant was convicted of, inter alia, murder with a firearm. The Appellate Court affirmed. Defendant appealed, arguing, in part, that the Appellate Court erred in determining that waiver of a claim of instructional error pursuant to State v. Kitchens precluded review of that claim under the plain error doctrine because the implied acquiescence of counsel cannot waive an error of such magnitude. The Supreme Court affirmed, holding (1) a Kitchens waiver does not necessarily foreclose plain error review of that same claim; but (2) the trial court’s decision not to instruct the jury on consciousness of guilt was not plain error. View "State v. McClain" on Justia Law

After a jury trial, Defendant was convicted of, among other charges, carrying a pistol without a permit and unlawful possession of a weapon in a vehicle. Defendant was sentenced to a total effective term of twelve years of incarceration. The appellate court reversed in part and affirmed in part, holding that the evidence was insufficient to sustain Defendant’s conviction for carrying a pistol without a permit and unlawful possession of a weapon in a vehicle because the State failed to offer direct evidence to prove that Defendant lacked a temporary state pistol permit issued by a town in the first instance. The Supreme Court reversed in part, holding (1) the jury reasonably could have concluded that the evidence established that Defendant did not possess any pistol permit beyond a reasonable doubt; and (2) therefore, Defendant was properly found guilty of carrying a pistol without a permit and unlawful possession of a weapon in a vehicle. View "State v. Davis" on Justia Law

After a jury trial, Defendant was convicted of murder. On appeal, Defendant’s principal claim was that the trial court violated his constitutional right to present a defense by refusing either to issue a summons to secure the attendance of a material witness in support of a theory of third-party culpability or to allow Defendant to introduce that witness’ statement to the police in lieu of her live testimony. The Supreme Court affirmed, holding (1) regarding Defendant’s argument regarding the issuance of a summons for the witness, defense counsel’s failure to locate the out-of-state witness with any reasonable degree of certainty precludes relief; and (2) none of Defendant’s remaining claims warrant reversal. View "State v. Bennett" on Justia Law

After a jury trial in 1997, Petitioner was found guilty of murder and criminal possession of a firearm. the trial court sentenced Petitioner to an aggregate term of sixty years’ imprisonment. Petitioner later filed an amended petition for a writ of habeas corpus containing four counts. The habeas court denied the petition. The appellate court affirmed, concluding that Petitioner failed to meet his burden of demonstrating that the deficient performance of defense counsel in responding to the trial court’s treatment of a jury note had prejudiced Petitioner. The Supreme Court affirmed, holding that Petitioner received constitutionally adequate representation at trial. View "Taylor v. Commissioner of Correction" on Justia Law

After a jury trial, Defendant was convicted of three counts of interfering with an officer. The Appellate Court reversed, concluding that the trial court abused its discretion in allowing the state to allow a midtrial amendment charging additional offenses. The Supreme Court affirmed, holding (1) the trial court abused its discretion in allowing the state to amend the information without good cause to charge additional offenses, but that impropriety does not require reversal in the absence of prejudice; and (2) the improper amendment was not harmless beyond a reasonable doubt under the circumstances of this case. View "State v. Ayala" on Justia Law

Petitioner was convicted of murder and other crimes. Petitioner filed a petition for writ of habeas corpus alleging ineffective assistance of counsel at Petitioner’s underlying criminal trial and on direct appeal. The petition was denied. Petitioner then filed a second habeas petition alleging ineffective assistance of habeas counsel in the first habeas proceeding. The habeas court denied the petition. Petitioner later filed a third habeas petition alleging, inter alia, ineffective assistance of habeas counsel in the second habeas proceeding. The habeas court dismissed these counts, concluding that Petitioner had failed to state a cognizable claim because the statutory right of indigent habeas petitions to counsel under Conn. Gen. Stat. 51-296(a) is limited to “effective representation by…first habeas counsel.” The Supreme Court reversed, holding that common law authorizes a third habeas petition as a proper vehicle to vindicate the right to competent assigned counsel in a second habeas proceeding. Remanded. View "Kaddah v. Commissioner of Correction" on Justia Law

After a jury trial, Defendant was found guilty of two counts of sexual assault in the first degree, three counts of sexual assault in the fourth degree and one count of risk of injury to a child. The convictions stemmed from allegations that Defendant sexually assaulted his girlfriend’s daughter. During the trial, the trial court granted the State’s motion in limine to exclude evidence of a prior allegation of sexual abuse made by the victim against her father’s then wife. Defendant appealed, arguing that the trial court erred in excluding evidence of the prior allegation and subsequent investigation. The Supreme Court dismissed the appeal as moot, as there were independent bases for the trial court’s exclusion of the evidence at issue that Defendant failed to challenge on appeal. View "State v. Lester" on Justia Law