Justia Connecticut Supreme Court Opinion Summaries

Defendant filed an application to be exempted from continued registration as a sex offender pursuant to Conn. Gen. Stat. 54-251(b). Following contested hearings, the trial court exempted Defendant from the continued obligation to register as a sex offender, finding that Defendant was under nineteen years of age at the time of the offense and that registration was not required for public safety. The State appealed, and the Appellate Court affirmed. The Supreme Court affirmed, holding that the Appellate Court properly concluded that the trial court had the authority to grant Defendant’s application for an exemption from registration approximately seven years after he had commenced registration, notwithstanding his agreement to register as a sex offender for ten years in his plea agreement with the State. View "State v. Obas" on Justia Law

Defendant was convicted of murder, assault in the first degree, criminal possession of a pistol, and risk of injury to a child. Defendant appealed, arguing that the trial court abused its discretion in failing to conduct an inquiry into his claim of juror misconduct. The Supreme Court reversed and remanded with instructions for the trial court to conduct an inquiry into Defendant’s claim. After approximately a decade, the trial court held the required inquiry and found no evidence of juror misconduct. The Supreme Court affirmed, holding (1) the trial court did not err in concluding that there was no evidence of juror misconduct; and (2) the delay on remand did not violate Defendant’s due process rights. View "State v. Roman" on Justia Law

After a jury trial, Defendant was convicted of robbery in the first degree. Defendant appealed, asserting that the trial court erred in denying his motion for a mistrial on the ground that his mother had tampered with the jury by approaching a juror outside the courthouse and speaking to him about the evidence in the case. The Supreme Court affirmed, holding (1) the presumption of prejudice in jury tampering cases set forth by the United States Supreme Court in Remmer v. United States remains good law in cases of external interference with the jury’s deliberative process via private communication, contact, or tampering with jurors about the pending matter; and (2) the State carried its burden of proving that the actions of Defendant’s mother did not lead to the reasonable possibility that any juror’s ability to decide this case fairly and impartially was affected. View "State v. Berrios" on Justia Law

Defendant was convicted of sexual assault in the first degree, among other crimes. The trial court sentenced Defendant to a term of imprisonment followed by probation. Defendant filed a motion to correct an illegal sentence, arguing that his sentence for first degree sexual assault was illegal because section 53a-70(b)(3) requires that persons convicted of that offense be sentenced to a term of imprisonment followed by a period of special parole. The trial court agreed with Defendant and sentenced him to a term of imprisonment and special parole for his conviction of first degree sexual assault. The Supreme Court reversed, holding that section 53a-70(b)(3) requires only that any period of special parole that may be imposed shall, along with the accompanying term of imprisonment, constitute a total sentence of not less than ten years. View "State v. Jason B." on Justia Law

Defendant was convicted of sexual assault in the first degree, among other crimes. The trial court sentenced Defendant to a term of imprisonment of twelve years for his conviction of sexual assault in the first degree, followed by probation. Defendant subsequently filed a motion to correct an allegedly illegal sentence, claiming that his sentence was illegal under Conn. Gen. Laws 53a-70(b)(3) because the sentence did not include a period of special parole. The trial court denied Defendant’s motion. The Supreme Court affirmed, holding that Defendant’s sentence was proper because section 53a-70(b)(3) does not require that persons convicted of first degree sexual assault be sentenced to a period of imprisonment and special parole; rather, it provides that if the court elects to impose such a sentence, then the total combined period of imprisonment and special parole must constitute a total sentence of not less than ten years. View "State v. Victor O." on Justia Law

After a jury trial, Defendant was convicted of murder. The appellate court affirmed, concluding that Defendant’s statements to her husband were not protected by the marital communications privilege pursuant to Conn. Gen. Stat. 54-84b. Specifically, the court determined that Defendant’s statements were not “induced by the affection” of the marital relationship, and therefore, the trial court did not err by admitting the statements. The Supreme Court affirmed, holding that because Defendant’s statements were not “induced by the affection, confidence, loyalty, and integrity of the marital relationship,” as required by section 54-84b(a), Defendant’s communications fell outside the marital communications privilege. View "State v. Davaloo" on Justia Law

After a jury trial, Defendant was convicted of assault in the second degree. The Appellate Court reversed, concluding that that Defendant was entitled to a new trial due to certain alleged improprieties that the prosecutor committed during his cross-examination of Defendant and in closing argument. Both parties appealed. The Supreme Court reversed, holding (1) the Appellate Court incorrectly concluded that Defendant was substantially prejudiced by the improprieties at issue in this case; (2) the trial court properly instructed the jury on the initial aggressor exception to self-defense; and (3) the trial court properly denied Defendant’s motion to suppress evidence of the knife that Defendant used during the assault. View "State v. Jones" on Justia Law

Defendant was convicted of possession of narcotics with intent to sell and conspiracy to possess narcotics with intent to sell. The Appellate Court reversed and ordered a new trial, concluding that the prosecutor violated a court order concerning the permissible boundaries of argument and referred to facts outside the record, thus rendering the trial fundamentally unfair. The State appealed, claiming that the prosecutor’s remarks were not improper. The Supreme Court reversed, holding that one of the prosecutor’s arguments was improper, but this improper argument did not deprive Defendant of his due process right to a fair trial because there was no reasonable likelihood that the prosecutor’s comments affected the jury’s verdict. View "State v. Martinez" on Justia Law

After a jury trial, Defendant was found guilty of conspiracy to commit assault in the first degree. Defendant appealed, claiming that his exclusion from an in chambers discussion regarding defense counsel’s possible conflict of interest violated his constitutional right to be present at all critical stages of the prosecution. The claim was unpreserved and so Defendant sought review pursuant to State v. Golding. The Appellate Court affirmed the judgment of conviction, determining that the record was inadequate to review the claim. The Supreme Court affirmed, holding that the record, as it presently stood, was not adequate for appellate review. View "State v. Walker" on Justia Law

After a jury trial, Defendant was convicted of two counts of aggravated sexual assault of a minor, in violation of Conn. Gen. Stat. 53a-70c(a)(1) and (6), and other offenses. Defendant sought review pursuant to State v. Golding, claiming that his convictions and sentences for two counts of aggravated sexual assault of a minor violate his right to be free of double jeopardy because they constitute multiple punishments for the same offense. The Supreme Court affirmed, holding that because subdivisions (1) and (6) of section 53a-70c(a) each require proof of a fact that the other does not, and because nothing in either the statutory text or legislative history of the statute reveals a contrary legislative intent, multiple convictions under section 53a-70c for the same transaction do not run afoul of the double jeopardy clause. View "State v. Wright" on Justia Law