Justia Connecticut Supreme Court Opinion Summaries

After a court trial, Defendant was convicted of breach of the peace in the second degree and harassment in the second degree. The Appellate Court reversed Defendant’s conviction for breach of the peace on the grounds of insufficient evidence and affirmed her harassment conviction. Both the State and Defendant appealed. The Supreme Court affirmed in part and reversed in part, holding that the Appellate Court (1) erred in concluding that there was insufficient evidence to support Defendant’s breach of the peace conviction; (2) did not err in concluding that there was sufficient evidence to support Defendant’s harassment conviction; and (3) did not abuse its discretion in declining to consider Defendant’s constitutional claims on the ground that they were inadequately briefed. View "State v. Buhl" on Justia Law

After a jury trial, Defendant was convicted of several crimes arising from his sexual assault of his three biological children, a daughter and two sons. The Appellate Court reversed, concluding that the trial court abused its discretion by permitting the three cases to be tried jointly and by allowing a dog to be present with the daughter during her testimony. The Supreme Court reversed, holding that the trial court properly exercised its discretion (1) in permitting the three cases to be tried together because the evidence in each case was cross admissible; and (2) in permitting a dog to sit near the daughter during her testimony to provide comfort and support. View "State v. Devon D." on Justia Law

Defendant challenged the Appellate Court's conclusion that he is not entitled to a new trial even though the record provides no support for the ruling of the trial court requiring that he remain shackled during his criminal trial. The court agreed with defendant that he should not have been shackled throughout the trial, but the court concluded that defendant has failed to establish that he was harmed by the shackling because, so far as the record reveals, the jury never saw the restraints. Accordingly, the court affirmed the judgment. View "State v. Brawley" on Justia Law

Defendant was charged with a number of crimes in connection with the abduction of his former wife. The trial judge found Defendant competent to represent himself at trial and permitted Defendant to represent himself. A jury subsequently convicted Defendant of all but one of the charges against him. The Supreme Court remanded the case to the trial court with direction to reconsider Defendant’s competency to represent himself in light of a new standard that the Court adopted in Defendant’s direct appeal. On remand, the trial judge concluded that Defendant had been competent to represent himself at the time of his trial. The Appellate Court reversed, concluding that the trial court’s remand hearing was procedurally flawed. The Supreme Court reversed, holding that the Appellate Court’s decision to resolve the appeal sua sponte on the basis that the remand hearing was procedurally flawed violated Blumberg Associates Worldwide, Inc. v. Brown & Brown of Connecticut, Inc. Remanded to the Appellate Court with direction to consider the issue raised in Defendant’s appeal. View "State v. Connor" on Justia Law

After a jury trial, Defendant was convicted of two counts of assault in the second degree. Defendant appealed, arguing that the trial court’s denial of his motion to suppress his statements to the police made during his booking violated his Fifth Amendment rights and that he was subjected to custodial interrogation without Miranda warnings at the crime scene. The Appellate Court affirmed, holding that the public safety exception to Miranda, as articulated in New York v. Quarles, applied. The Supreme Court affirmed, holding that, based on the circumstances of this case, the public safety exception applied. View "State v. Smith" on Justia Law

After a jury trial, Defendant was convicted of both intentional and reckless assault in the first degree. Defendant filed a motion for a new trial, arguing that the convictions were legally inconsistent. The trial court denied the motion. The Appellate Court reversed, concluding that Defendant’s convictions for intentional and reckless assault were legally inconsistent. The Supreme Court reversed, holding (1) Defendant’s convictions were not legally inconsistent under the State’s argument that the assault occurred in two reckless and intentional phases, respectively; and (2) Defendant had sufficient notice that he could be convicted of both reckless and intentional assault, and therefore, the manner in which Defendant was convicted satisfied the requirements of due process. View "State v. King" on Justia Law

Petitioner was convicted of sexual assault in the first degree and kidnapping in the first degree. Thereafter, in State v. Salamon and Luurtsema v. Comm’r of Corr. (Luurtsema II), the Supreme Court overruled its overly broad interpretation of its kidnapping statutes and determined the holding in Salamon applied retroactively to collateral attacks on final judgments. Petitioner subsequently filed a second petition for a writ of habeas corpus arguing that there was constitutional error in the kidnapping instruction pursuant to Salamon and Luurtsema II. The habeas court granted a new trial on the kidnapping charge and rejected the Commissioner of Correction’s assertion that Petitioner’s failure to challenge the Court’s long-standing interpretation of kidnapping in his criminal proceedings led to his procedural default. The Appellate Court affirmed. The Supreme Court affirmed, holding (1) Luurtsema II’s retroactivity decision compels the conclusion that challenges to kidnapping instructions in criminal proceedings rendered final before Salamon are not subject to the procedural default rule; and (2) Petitioner was entitled to a new trial on the kidnapping charge because the omission of a Salamon instruction was not harmless beyond a reasonable doubt. View "Hinds v. Comm’r of Corr." on Justia Law

Defendant entered a guilty plea under the Alford doctrine to one count of sexual assault in the first degree. At the sentencing hearing, Defendant requested that he be permitted to withdraw his plea. The trial court denied the motion. Defendant appealed, arguing that the trial court erred in denying his oral motion to withdraw his plea “without any type of inquiry or evidentiary hearing as to the underlying basis of [his] motion.” The Appellate Court affirmed, concluding that the inquiry conducted by the court was sufficient. The Supreme Court affirmed, holding that the trial court did not abuse its discretion in denying Defendant’s motion to withdraw his guilty plea without conducting a further inquiry into the underlying basis of Defendant’s motion. View "State v. Anthony D." on Justia Law

Defendant was convicted of two counts of aggravated sexual assault and one count each of conspiracy to commit aggravated sexual assault in the first degree, conspiracy to commit kidnapping in the first degree, and assault in the third degree. The Appellate Court remanded the case to the trial court with direction to vacate the judgment as to two of the conspiracy counts and to render judgment on one of the conspiracy counts, concluding that Defendant’s sentence on all three conspiracy counts, which were based on a single agreement with multiple criminal objectives, violated the double jeopardy clause of the federal Constitution. Both Defendant and the State appealed. The Supreme Court affirmed, holding (1) the trial court erred in limiting Defendant’s ability to present evidence of the victim’s prior sexual conduct, but the error was harmless beyond a reasonable doubt; and (2) the Appellate Court correctly concluded that vacatur was the appropriate remedy for the double jeopardy violation. View "State v. Wright" on Justia Law

Defendant was convicted of two counts of sexual assault in the first degree and two counts of risk of injury to a child. On appeal, Defendant challenged his convictions on statute of limitations grounds. The Appellate Court reversed the convictions, concluding that of the four counts in the operative informations, one count was completely time barred and the other three counts were partially untimely. The court remanded the case for a new trial as to the charges that were not time barred. The State subsequently filed a substitute information charging Defendant with two counts of kidnapping in the first degree. On remand, the trial court granted Defendant’s motion to dismiss the substitute information, ruling that the scope of the remand order precluded the State from amending its information. The Appellate Court reversed. The Supreme Court affirmed, holding that the Appellate Court (1) properly concluded that its remand order did not preclude the State from filing the substitute information; and (2) properly concluded that the kidnapping charges in the State’s substitute information were not barred by the doctrine of res judicata. View "State v. Brundage" on Justia Law