Justia Connecticut Supreme Court Opinion Summaries

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

Defendant was charged with murder and other offenses. In 2010, the trial court found Defendant incompetent to stand trial. Thereafter, a judge found that Defendant had been restored to competency and granted his motion to represent himself. In 2015, the trial court again found Defendant incompetent to stand trial. After evidentiary hearings, the trial court granted the State’s motion for forcible medication of Defendant, finding that the State had established that forced medication would not violate Defendant’s federal due process rights under the test set forth by the United States Supreme Court in Sell v. United States. The Supreme Court affirmed, holding that the trial court correctly determined that forced medication was “substantially likely” to render Defendant competent to stand trial. View "State v. Wang" on Justia Law

Defendant entered a conditional plea of nolo contendere to possession of narcotics with intent to sell and failure to appear in the first degree. Defendant appealed, arguing that the trial court erred in denying Defendant’s motion to suppress narcotics evidence. The appellate court affirmed, concluding (1) the trial court correctly determined that Defendant was not seized until police officers performed a patdown search for weapons, and (2) the record was inadequate to review Defendant’s claim that he was unreasonably seized when two police cruisers descended upon him in a small parking lot and an officer verbally commanded him to stop. The Supreme Court reversed, holding (1) the appellate court erred in concluding that Defendant was not seized until the officers patted him down for weapons and that certain of Defendant's claims in that regard were unreviewable; and (2) the evidence Defendant sought to suppress was seized in violation of the federal and state constitutions. View "State v. Edmonds" on Justia Law

Defendant was found guilty by a jury of burglary in the third degree and larceny in the third degree. The Appellate Court reversed defendant's convictions, concluding that it was plain error for the trial court not to instruct the jury, as mandated by General Statutes 54-84 (b), that it may draw no unfavorable inferences from defendant's failure to testify. The court granted the state’s petition for certification to appeal, limited to the issue of whether the Appellate Court properly reversed defendant’s conviction under the plain error doctrine. The court concluded that, even if a violation of section 54-84 (b) is subject to harmless error analysis, the state cannot establish that the violation in the present case was harmless beyond a reasonable doubt. Accordingly, the court affirmed the judgment. View "State v. Ruocco" on Justia Law

After a jury trial, Petitioner was found guilty of sexual assault and risk of injury. Petitioner failed to appeal from the judgment of conviction. Thereafter, Petitioner filed a petition for a writ of habeas corpus alleging that the trial court had conducted an inadequate canvass and erroneously concluded that Petitioner knowingly, intelligently and voluntarily waived his right to counsel. The habeas court granted the petition and ordered a new trial, concluding that the public defender’s office had erred in determining that Petitioner was ineligible for the assistance of counsel. The Appellate Court affirmed. The Supreme Court reversed, holding (1) the Appellate Court incorrectly concluded that Petitioner had advanced a claim of public defender error in the habeas court; and (2) the issue of whether Petitioner’s claims were procedurally defaulted was not properly before the Court. Remanded. View "Newland v. Comm’r of Corr." on Justia Law

After a jury trial, Defendant was convicted of two counts of sexual assault in the first degree and one count of risk of injury to a child. The Supreme Court affirmed as modified, holding (1) the trial court properly instructed the jury on the use of constancy of accusation evidence; (2) the constancy of accusation doctrine should be modified to address the potential prejudice to defendants caused by the testimony of multiple constancy witnesses; and (3) there is no reason to order a new trial when testimony, such as that presented in the instant case, has been properly admitted under the Court’s former articulation of the constancy of accusation doctrine. View "State v. Daniel W. E." on Justia Law

After a jury trial, Defendant was found guilty of sexual assault in the first degree. The Appellate Court affirmed the conviction, concluding that the trial court erred in excluding a prospective juror for cause on the ground that he was “not able to speak and understand the English language” within the meaning of Conn. Gen. Stat. 51-217(a)(3), but the error was not prejudicial. Defendant appealed, arguing that the trial court’s purportedly improper exclusion of the prospective juror should constitute per se reversible error. The Supreme Court affirmed, holding (1) the Appellate Court did not err in determining that the trial court’s excusal of the prospective juror for cause under Conn. Gen. Stat. 51-217(a)(3) was subject to reversal only upon a showing of prejudice; and (2) the improper removal of the prospective juror did not entitle Defendant to a new trial in the absence of a showing of prejudice. View "State v. Gould" on Justia Law