Justia Connecticut Supreme Court Opinion Summaries

Petitioner was convicted of sexual assault in the first degree and risk of injury to a child for sexually abusing a four-year-old girl. Petitioner subsequently filed a petition for a writ of habeas corpus, alleging that his counsel provided ineffective assistance by failing to present expert testimony regarding the suggestibility of young children and the reliability of a child’s recollection of sexual abuse. The habeas court reversed, concluding that Petitioner established that his trial counsel had rendered ineffective assistance. The Appellate Court affirmed. The Supreme Court reversed, holding that the failure of Petitioner’s trial counsel to present the expert testimony was objectively reasonable because there was a legitimate, strategic reason for not presenting such testimony. View "Michael T. v. Comm’r of Corr." on Justia Law

Pursuant to a plea agreement, Petitioner pleaded guilty to manslaughter in the first degree with a firearm. The plea agreement stated that Petitioner would receive a total sentence of between twenty and twenty-five years’ imprisonment and that defense counsel had a right to argue for a sentence beneath the twenty-five year cap. At sentencing, defense counsel agreed with the prosecutor’s recommendation that the trial court should impose the maximum sentence under the agreement. The trial court sentenced Petitioner to twenty-five years imprisonment. Petitioner subsequently filed a petition for a writ of habeas corpus, claiming ineffective assistance of counsel. The habeas court denied relief, determining that Petitioner failed to prove ineffective assistance of counsel under Strickland v. Washington. The Appellate Court affirmed, concluding that the habeas court properly determined that Petitioner failed to prove actual prejudice under Strickland. The Supreme Court reversed in part, holding that the habeas court improperly applied Strickland to Petitioner’s ineffective assistance claim because a complete breakdown in the adversarial process occurred, and therefore, Petitioner’s claim was instead controlled by United States v. Cronic, under which prejudice should be presumed. View "Davis v. Comm’r of Corr." on Justia Law

After a jury trial, Defendant was found guilty of larceny in the third degree. The State sought to have Defendant’s sentence enhanced under Conn. Gen. Stat. 53a-40b because Defendant had committed the larceny while he was released on bond. Prior to the hearing on the sentence enhancement, the records for Defendant’s previous arrests had been erased in accordance with Conn. Gen. Stat. 54-142a. The trial court allowed the State to introduce those records into evidence and, relying solely on those records, found that Defendant had committed the larceny while he was on release. The Appellate Court reversed, concluding that the trial court had improperly allowed the State to introduce the erased records and that the State could not seek to prove the basis for the sentence enhancement at a new hearing. The Supreme Court reversed in part, holding (1) the trial court improperly permitted the State to introduce the erased records to prove the basis for the sentence enhancement under section 53a-40b; but (2) on remand, the State is not foreclosed from seeking to establish the basis for Defendant’s sentence enhancement by use of evidence other than the erased records. View "State v. Apt" on Justia Law

Defendant was found not guilty of certain offenses by reason of mental disease or defect and transferred to a maximum security psychiatric facility. Defendant was charged with new, violent crimes while housed at the facility. The trial court set a monetary bond as a condition of release. Because Defendant was unable to post that bond, he was transferred to the custody of the Commissioner of Correction at a prison while awaiting trial on the new charges. Defendant appealed. The Supreme Court affirmed, holding that the trial court’s imposition of a monetary bond and, after Defendant was unable to post that bond, Defendant’s transfer to the custody of the Commissioner, did not violate Defendant’s constitutional rights to (1) bail, pursuant to the Connecticut Constitution; and (2) procedural due process, pursuant to the Fourteenth Amendment to the United States Constitution. View "State v. Anderson" on Justia Law

Defendant entered conditional pleas of nolo contendere to possession of a controlled substance with intent to sell, home invasion, robbery in the second degree, burglary in the third degree, a stealing a firearm. Defendant appealed the trial court’s denial of his motion to suppress evidence of statements he made to the police following his arrest, in which he confessed to the charged crimes. Specifically, Defendant argued that his statements should have been suppressed as the product of an illegal search because the warrant authorizing the search of his apartment was unsupported by probable cause. The Appellate Court affirmed. The Supreme Court affirmed, holding that the affidavit in support of the search warrant application established probable cause, and accordingly, the Appellate Court properly affirmed the trial court’s denial of Defendant’s motion to suppress. View "State v. Flores" on Justia Law

Petitioner was convicted of reckless endangerment in the second degree and related offenses. Petitioner filed a petition for writ of habeas corpus, claiming that his trial counsel rendered ineffective assistance at his criminal trial because she chose not to pursue questioning of a potential exculpatory witness. The habeas court denied the petition. The Appellate Court dismissed Petitioner’s appeal, concluding that substantial evidence supported the habeas court’s conclusion that Petitioner had failed to establish the prejudice prong for ineffective assistance of counsel under Strickland v. Washington. The Supreme Court affirmed, holding that the Appellate Court properly dismissed Petitioner’s appeal on the ground that he had failed to satisfy the prejudice prong of Strickland. View "Staton v. Comm’r of Corr." on Justia Law

After a jury trial, Defendant was found guilty of two counts of sexual assault in the third degree, once count of sexual assault in the fourth degree, and three counts of risk of injury to a child. The Appellate Court reversed Defendant’s conviction and remanded the case for a new trial, concluding that the prosecutor’s statements during closing argument deprived Defendant of his due process right to a fair trial. The Supreme Court reversed the judgment of the Appellate Court, holding that the majority of the challenged remarks were not improper and that the remaining remark did not deprive Defendant of a fair trial. View "State v. Felix R." on Justia Law

Defendant was convicted of kidnapping in the second degree and interfering with an officer. On appeal, Defendant argued, among other claims, that the trial court improperly denied him his right to self-representation because the denial was based on incorrect grounds - the adequacy of defense counsel. The Appellate Court agreed and reversed, concluding that the trial court’s denial of Defendant’s motion to proceed pro se was improper and that the improper ruling was structural error. The Supreme Court affirmed, holding (1) the trial court’s denial of Defendant’s request to represent himself was clear and conclusive, and therefore, Defendant’s subsequent conduct did not effect a waiver of his right to self-representation; and (2) the trial court’s denial of Defendant’s request was improper, and the improper denial of the request was structural error. View "State v. Braswell" on Justia Law

After a jury trial, Defendant was convicted of larceny in the first degree and conspiracy to commit larceny in the first degree. The convictions were based in part on evidence that included warrantless recordings of telephone conversations between Defendant and Jacqueline Becker, which were recorded without Defendant’s consent but with the consent of Becker. The Supreme Court affirmed the convictions, holding (1) recording a telephone conversation with the consent of one party to that conversation does not violate the prohibition on unreasonable searches and seizures under the Connecticut Constitution; and (2) the trial court’s failure to conduct an independent inquiry regarding Defendant’s competence to stand trial was not improper. View "State v. Skok" on Justia Law

Defendant was charged in separate informations with the murders of Rene Pellegrino and Michelle Comeau. The trial court granted the State’s motion to consolidate the cases based on the cross admissibility of the evidence. After a joint trial of both the Comeau and Pellegrino cases, the jury found Defendant guilty of the Pellegrino murder but was unable to reach a verdict in the Comeau case. The trial court rendered judgment in accordance with the jury verdict in the Pellegrino case and declared a mistrial in the Comeau case. On appeal from the judgment of conviction in the Pellegrino case, Defendant claimed that the trial court abused its discretion consolidating the cases for trial. The Supreme Court affirmed, holding that the trial court did not abuse its discretion in consolidating the Pellegrino and Comeau cases for trial on the basis of the cross admissibility of the evidence in the two cases. View "State v. Anderson" on Justia Law