Justia Connecticut Supreme Court Opinion Summaries

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

Defendant entered a conditional plea of nolo contendere to possession of a controlled substance with intent to sell. Prior to entering the plea, Defendant moved to suppress evidence seized from his vehicle, claiming that the police did not possess a reasonable and articulable suspicion that he was engaged in or about to engage in criminal activity. On appeal, Defendant challenged the the trial court’s denial of his motion to suppress. The Appellate Court reversed, concluding that the trial court’s determination that the police possessed a reasonable and articulable suspicion that criminal activity was afoot when they detained Defendant was incorrect. The Supreme Court reversed, holding that, under the totality of the circumstances, the police possessed a reasonable and articulable suspicion to detain Defendant outside a known drug location where Defendant had previously acted in a manner consistent with drug activity. View "State v. Peterson" on Justia Law

In two separate cases, in 2005 and 2007, Defendant was convicted of two offenses. In 2009, the trial court found that Defendant violated the conditions of his probation and sentenced him to serve the entirety of his original 2005 sentence. Later that day, Defendant entered an Alford plea pleading guilty to attempt to commit arson in the second degree. Defendant appealed the judgment of the trial court finding him in violation of his 2005 probation, arguing that the evidence was insufficient to support the finding that he violated the terms of his probation. Defendant did not take a timely appeal challenging his guilty plea to the charge of attempt to commit arson but did file a petition for habeas corpus challenging his guilty plea. The Appellate Court dismissed Defendant’s sufficiency challenge as moot, concluding that Defendant’s guilty plea to the arson charge established that he had violated the terms of his 2005 probation. The Supreme Court affirmed, holding (1) a habeas corpus petition, unlike a direct appeal, does not keep alive a defendant’s claim that there was insufficient evidence to find him in violation of his probation; and (2) the Appellate Court properly determined that Defendant rendered moot his insufficiency of the evidence claim. View "State v. Rodriguez" on Justia Law

Defendant pleaded guilty to harassment in the second degree and criminal trespass in the first degree and was sentenced to one year incarceration, execution suspended, and two years of probation. Defendant was later charged with violating the conditions of his probation. After a hearing, the trial court found that Defendant violated the conditions of his probation, continued Defendant’s probation, and added new conditions. The Supreme Court affirmed, holding (1) the trial court properly admitted evidence that Defendant argued should have been suppressed; (2) the evidence was sufficient to demonstrate that Defendant violated the terms of his probation; (3) the trial court did not err in admitting certain hearsay evidence; and (4) Defendant waived his Second Amendment right to possess firearms when he agreed to the condition of his probation barring him from possessing firearms. View "State v. Maietta" on Justia Law

After a jury trial, Defendant was convicted of illegal possession of an explosive and manufacturing a bomb. The Appellate Court reversed in part the judgment of the trial court, concluding that the trial court committed plain error by not providing an accomplice credibility instruction, sua sponte, to the jury. The Supreme Court reversed in part the judgment of the Appellate Court, holding (1) the trial court’s failure to give an accomplice credibility instruction did not constitute plain error; and (2) it is unnecessary to reach the merits of Defendant’s alternative ground for affirmance, namely, that the trial court violated Defendant's constitutional rights by compelling him to provide a handwriting exemplar, as any alleged error was harmless. View "State v. Jamison" on Justia Law

After a jury trial, Defendant was convicted in two consolidated cases of attempted murder, two counts of risk of injury to a child, and murder. The Supreme Court reversed, concluding that the trial court improperly granted the State’s motion to disqualify his chosen attorney, Gary Mastronardi, and that the improper disqualification was structural error requiring a new trial. On remand, Defendant filed a motion asking the State to fund Mastronardi’s private fee or, alternatively, to dismiss the charges against him on the grounds that he was now indigent and tat Mastronardi would not represent him at the new trial at the rate paid to assigned counsel by the Division of Public Defender Services. The trial court denied Defendant’s motion, concluding that the Supreme Court’s decision Peeler I did not require it. After a second jury trial, Defendant was found guilty on all counts. The Supreme Court affirmed, holding that the trial court did not violate Defendant’s right to counsel of choice at his new trial by denying his funding motion. View "State v. Peeler" on Justia Law

After a jury trial, Defendant was convicted of crimes committing during a string of armed robberies in the cities of Stamford and Norwalk and the town of Greenwich. Defendant appealed, arguing (1) his constitutional right to counsel was violated when the trial court admitted incriminating statements he made regarding the Norwalk and Greenwich robberies while he was represented by counsel in the case involving the Stamford robbery; and (2) the trial court violated his constitutional right to confrontation by restricting defense counsel’s cross-examination of a key prosecution witness. The Supreme Court affirmed, holding that the trial court’s admission of the incriminating statements and its restrictions on counsel’s cross-examination of the witness did not violate Defendant’s Sixth Amendment rights or constitute an abuse of discretion. View "State v. Leconte" on Justia Law