Justia Connecticut Supreme Court Opinion Summaries

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

After a jury trial, Defendant was convicted of assault in the second degree and attempt to commit assault in the first degree. Defendant appealed, asserting that the trial court erred in its instructions to the jury. The Supreme Court affirmed, holding (1) the trial court correctly charged the jury on the subjective portion of the subjective-objective test for determining entitlement to self-defense; (2) the trial court properly charged the jury that Defendant was required to demonstrate that she had actual knowledge, rather than merely a reasonable belief, that the victim had violated the terms of their mutual combat by agreement; and (3) the jury instructions properly articulated the State’s burden of proof with respect to self-defense generally and combat by agreement specifically. View "State v. O'Bryan" on Justia Law

After a jury trial, Defendant was convicted of murder, kidnapping in the second degree, and felony murder. The Supreme Court affirmed, holding (1) the prosecutor engaged in impropriety during the cross-examination of Defendant’s expert witness, but the instances of impropriety did not violate Defendant’s right to a fair trial and, therefore, did not warrant reversal of his conviction; (2) the trial court did not err in denying Defendant’s motions for a mistrial based on the improper presentation of uncharged misconduct evidence; (3) the evidence was sufficient to support Defendant’s kidnapping conviction; and (4) the trial court did not err in precluding that testimony of two witnesses on the basis of hearsay and relevance. View "State v. O'Brien-Veader" on Justia Law

After a jury trial, Defendant was convicted of murder. The Supreme Court affirmed, holding (1) Defendant did not preserve his claim that the trial court had an obligation to provide, sua sponte, a jury instruction on the risk of misidentification by an eyewitness pursuant to State v. Ledbetter; (2) the trial court did not abuse its discretion in the manner in which it conducted its inquiry into the allegation of juror bias; and (3) Defendant’s exclusion from the hearing concerning possible juror bias was not a violation of his constitutional rights to be present at a critical stage of the proceedings, to counsel, and to be presumed innocent. View "State v. Dixon" on Justia Law

After a jury trial, Defendant was convicted of first degree assault, first degree unlawful restraint, and carrying a dangerous instrument. Defendant appealed, claiming that his constitutional rights to confrontation, to present a defense and to due process were violated when the trial court disclosed only four pages of the psychiatric records of E.P., a state witness, and prohibited Defendant from consulting with an expert witness as to the four disclosed pages. The Appellate Court affirmed. The Supreme Court affirmed, holding that any error in releasing only four pages of E.P.’s psychiatric records and in limiting Defendant’s ability to consult with an expert as to the disclosed pages was harmless beyond a reasonable doubt. View "State v. Santos" on Justia Law