Justia Connecticut Supreme Court Opinion Summaries

Defendant lived in a unit of a multiunit condominium complex. When the police department received an anonymous tip that Defendant was boasting about growing marijuana in his unit, the police entered the building with a drug dog and conducted a directed search in which the dog sniffed at the common floor hallways and at the bottom of the door to Defendant’s unit. The officers later returned with a search warrant, and Defendant was subsequently arrested and charged with several drug offenses and illegal possession of an assault weapon. Defendant filed a motion to suppress, arguing that the canine sniff of the threshold of his unit for the purpose of investigating the unit’s contents constituted a search within the meaning of article first, section seven of the Connecticut Constitution and the Fourth Amendment of the United States Constitution. The trial court granted the motion to suppress, concluding that the canine sniff constituted a search within the meaning of the Fourth Amendment and, therefore, required a warrant predicated on probable cause. The Supreme Court affirmed, holding that a canine sniff directed toward a home is a search under article first, section seven of the Connecticut Constitution and, as such, requires a warrant issued upon a court’s finding of probable cause. View "State v. Kono" on Justia Law

Defendant was charged by criminal information with sexual assault in the first degree and risk of injury to a child. Based on the seriousness of the offenses and the allegation that Defendant’s conduct occurred when he was fourteen years old, the case was automatically transferred from the juvenile docket to the regular criminal docket. After a jury trial, Defendant was convicted of two counts of sexual assault int he first degree and one count of risk of injury to a child. The Appellate Court vacated the convictions, concluding that the trial court erred by denying Defendant’s post trial motion to dismiss the information because the State had failed to prove beyond a reasonable doubt that the conduct underlying the convictions had occurred after Defendant’s fourteenth birthday. The Supreme Court affirmed, holding that the State did not establish, under any burden of proof, that Defendant was at least fourteen years old at the time he committed the offenses for which he was convicted. View "State v. Samuel M." on Justia Law

Defendant was convicted of murder. Defendant committed the crime when he was seventeen years old. In 1992, Defendant was sentenced to fifty years’ imprisonment without parole. In 2013, Defendant filed a motion to correct his allegedly illegal sentence, arguing that he was entitled to resentencing on the basis of recent changes to juvenile sentencing law. The trial court dismissed the motion for lack of jurisdiction. The Supreme Court affirmed, holding that court precedent does not require a trial court to consider any particular mitigating factors associated with a juvenile’s age before imposing a sentence that includes an opportunity for parole, and therefore, Defendant has not raised a colorable claim of invalidity that would require resentencing. View "State v. Boyd" on Justia Law

In 1996, Defendant was sentenced to sixty-five years imprisonment without parole for crimes that he committed when he was a juvenile. Under recent changes to juvenile sentencing law, a juvenile who has been convicted of murder to life in prison without parole may not be sentenced to life in prison unless the court considers mitigating factors associated with the juvenile’s age at the time of the crimes. Defendant was sentenced before these changes occurred. In 2014, Defendant filed a motion to correct his allegedly illegal sentence, arguing that the judge who sentenced him failed to consider youth-related mitigating factors. The trial court dismissed Defendant’s motion to correct. The Supreme Court affirmed, holding that the sentencing court lacked jurisdiction to correct the sentence, as Defendant did not claim that the sentence was illegal or was imposed in an illegal manner. View "State v. Delgado" on Justia Law

After a second jury trial, Defendant was found guilty of one count of sexual assault in the fourth degree. The Appellate Court affirmed, concluding that the trial court properly denied Defendant’s request to strike a juror for cause even when Defendant had shown that the juror was a police officer with possible ties to the agency investigating Defendant’s case. Defendant appealed, claiming that the challenged juror’s bias should have been conclusively presumed. The Supreme Court affirmed, holding that there was an insufficient factual basis for the trial court to find the type of close relationship between the challenged juror and a party or witness that would require disqualification as a matter of law, and therefore, the trial court did not err in denying Defendant’s challenge with respect to that juror. View "State v. Benedict" on Justia Law

In 2006, Angel Agron was arrested and charged with several offenses. The trial court set bail on these charges in an amount totaling $20,000. 3-D Bail Bonds (Plaintiff) executed a bail on that amount, and Agron was released from custody. When Agron did not appear for a scheduled court date, the trial court ordered the total amount of the bond forfeited. Plaintiff filed a motion to release Plaintiff from its obligation on the bond pursuant to Conn. Gen. Stat. 54-65c, asserting that Agron was “detained” in Puerto Rico by bail enforcement agents. The trial court denied the motion. Plaintiff thereafter filed a writ of error. The Supreme Court dismissed the writ of error, holding that the trial court did not err in concluding that Agron was not “detained” for purposes of section 54-65c when he was personally confronted by recovery bail enforcement agents in Puerto Rico. View "State v. Agron" on Justia Law

After a jury trial, Defendant was convicted of murder, using a firearm in the commission of a felony, carrying a pistol without a permit, and criminal possession of a pistol or revolver. The trial court sentenced Defendant to seventy years of incarceration. Defendant appealed, arguing that the trial court abused its discretion in admitting a Facebook profile page and photographs. Specifically, Defendant argued that the evidence was not properly authenticated. The Supreme Court affirmed, holding that, assuming, without deciding, that the trial court improperly admitted the evidence, any error relating to the admission of the evidence would have been harmless. View "State v. Bouknight" on Justia Law

After a jury trial, Defendant was convicted of conspiracy to distribute one kilogram or more of a cannabis-type substance and possession of one kilogram or more of a cannabis-type substance with intent to sell as an accessory. Defendant appealed, claiming that the trial court had incorrectly instructed the jury on the state of mind required to find him guilty of the offenses. Applying the waiver rule in State v. Kitchens, the Appellate Court concluded that Defendant failed to preserve his claim. Defendant appealed, requesting that the waiver rule established in Kitchens be overturned and that his claim be reviewed under State v. Golding. The Supreme Court affirmed, holding (1) the rule in Kitchens should not be overturned; and (2) Defendant’s request to review his claim under the plain error doctrine is declined because such review is beyond the scope of the certified question. View "State v. Herring" on Justia Law

After a jury trial, Defendant was convicted of two counts of murder and other crimes. Defendant appealed, claiming, inter alia, that the jury instructions on the issue of the accuracy of an identification were prejudicially erroneous and deprived him of a fair trial. Applying the waiver rule in State v. Kitchens, the Appellate Court ultimately concluded that the claim had been waived. The Supreme Court affirmed, holding (1) the Appellate Court did not err in concluding that Defendant waived his unpreserved jury instruction under the rule established in Kitchens; and (2) the rule in Kitchens should not be overturned. View "State v. Bellamy" on Justia Law

In 2015, the legislature amended the juvenile transfer statute to increase the age of a child whose case was subject to an automatic transfer to the regular criminal docket by one year, to fifteen years old. Automatic transfer is required in cases involving children who have been charged with the commission of a class A or class B felony. At issue in this case was whether that amendment applied retroactively so that the case of a child, such as Defendant, who had been charged with committing a class A or class B felony prior to the amendment for crimes he committed when he was fourteen years old, and whose case had already been transferred to the regular criminal docket, should have his case transferred back to the juvenile docket. The trial court reserved this question of law for the advice of the Supreme Court. The Supreme Court granted the request and answered the question in the affirmative, concluding that the legislature intended that the amendment apply retroactively. View "State v. Nathaniel S." on Justia Law