Justia Connecticut Supreme Court Opinion Summaries

Defendant was found guilty of capital felony and sentenced to death. While Defendant’s appeal was pending, the legislature passed Public Act 12-5, which repealed the death penalty for all crimes committed on or after April 25, 2012. On June 12, 2012, the Supreme Court affirmed Defendant’s judgment of conviction but reversed his death sentence and remanded for a new penalty phase hearing, concluding that the trial court improperly had failed to disclose to Defendant certain confidential records that were mitigating in nature. Defendant filed a motion for reconsideration, claiming that the adoption of P.A. 12-5 leads to the conclusion that capital punishment has ceased to comport with state constitutional requirements. The Supreme Court agreed and reversed Defendant’s sentence of death on the capital felony count, holding that the enactment of P.A. 12-5, when considered in light of the history of the death penalty in the state and other recent legal developments, compels the conclusion that capital punishment, as currently applied, constitutes cruel and unusual punishment in violation of the constitution of Connecticut. Remanded with direction to sentence Defendant to life imprisonment without the possibility of release. View "State v. Santiago" on Justia Law

After a jury trial, Defendant was convicted of attempt to commit assault in the first degree and various other offenses. The Appellate Court affirmed the judgment of conviction. The Supreme Court affirmed, holding (1) there was sufficient evidence to establish beyond a reasonable doubt Defendant’s intent to inflict serious physical injury on another, as required for a conviction of attempt to commit assault in the first degree; and (2) the Appellate Court properly determined that there was sufficient evidence for a conviction of that offense under a view of the evidence that was fully consistent with the state’s theory at trial. View "State v. Carter" on Justia Law

After a jury trial, Defendant was convicted of murder as an accessory and felony murder. On appeal, Defendant argued that the evidence was insufficient to support his conviction of murder as an accessory and that the trial court erred in failing to instruct the jury, sua sponte, on the defense of duress. The Supreme Court affirmed the judgment of the trial court, holding (1) the evidence was sufficient for the jury to find Defendant guilty of murder as an accessory; and (2) the trial court did not improperly fail to instruct the jury, sua sponte, on a defense of duress. View "State v. Bonilla" on Justia Law

After a jury trial, Defendant was convicted of capital felony, murder, and felony murder. The convictions arose from the killing of a single victim. The Appellate Court reversed in part and and remanded the case with direction to vacate Defendant’s convictions of murder and felony murder, concluding that those convictions violated constitutional protections against double jeopardy because they were cumulative of the controlling conviction of capital felony. The State appealed, asserting that vacatur was not the appropriate remedy for Defendant’s cumulative conviction of felony murder that violated his double jeopardy protections. The Supreme Court affirmed, holding that the vacatur remedy set forth in State v. Polanco should extend to scenarios like Defendant’s, thus making it appropriate to vacate his cumulative felony murder conviction. View "State v. Miranda" on Justia Law

After a jury trial, Defendant was convicted of two counts of robbery in the first degree, two counts of unlawful restraint in the first degree, and being a persistent dangerous felony offender. Defendant appealed, arguing that the trial court abused its discretion in precluding testimony from Defendant’s expert witness on the fallibility of eyewitness identifications. The Appellate Court affirmed, holding that the eyewitness in question had sufficient prior familiarity and contact with Defendant such as to make her identification of him reliable, and therefore, the trial court did not abuse its discretion in precluding Defendant’s expert from testifying. The Supreme Court affirmed, holding that the eyewitness’s previous contact with Defendant made the trial court’s decision to exclude the expert testimony on the fallibility of eyewitness identification an appropriate exercise of its discretion. View "State v. Williams" on Justia Law

Petitioner pleaded nolo contendere to a charge of assault in the first degree. Petitioner filed an amended habeas petition alleging that his trial counsel had failed to provide sufficient information to enable him to make an informed decision about whether to plead nolo contendere or to proceed to trial. The habeas court denied the petition, concluding that Petitioner was not prejudiced by his counsel’s alleged errors. The Appellate Court reversed, concluding that the prejudice standard enunciated in Copas v. Commissioner of Correction that the habeas court applied in this case was inconsistent with federal law concerning the prejudice prong. The Commissioner of Correction appealed, claiming that the Appellate Court improperly determined that the habeas court applied an incorrect legal standard. The Supreme Court dismissed the appeal for lack of subject matter jurisdiction, as the Commissioner was not aggrieved by the judgment of the Appellate Court and Copas has already been overruled sub silencio in subsequent decisions by the Court. View "Carraway v. Comm’r of Corr." on Justia Law

Plaintiff pleaded guilty to four counts of sexual assault in the fourth degree in violation of Conn. Gen. Stat. 53a-73a(a)(2). The United States Department of Homeland Security subsequently commenced removal proceedings against Plaintiff on the ground that he was convicted of two or more crimes involving moral turpitude. The immigration judge determined that section 53a-73a(a)(2) is not a crime involving moral turpitude because the statute does not require that the actor know that his actions were not consented to by the victim. The Board of Immigration Appeals reversed. The United States Court of Appeals for the Second Circuit concluded that resolving the issue of what mens rea was required for the lack of consent element of the statute was necessary to determine whether the plaintiff had been convicted of a crime of moral turpitude and certified questions to the Connecticut Supreme Court regarding section 53a-73a(a)(2). The Supreme Court answered (1) section 53a-73a(a)(2) is not a strict liability offense with respect to the lack of consent element; and (2) the mens rea applicable to the element of consent in section 53a-73a(a)(2) is criminal negligence. View "Efstathiadis v. Holder" on Justia Law

After a jury trial, Defendant was convicted of murder. On appeal, Defendant argued, among other things, that he was entitled to a new trial because the trial court improperly forced him to choose between his constitutional right to counsel and his constitutional right to testify on his own behalf after defense counsel stated that he would be self-represented if he testified against their advice. The Appellate Division affirmed, concluding that Defendant waived his right to counsel when he elected to testify at trial. The Supreme Court reversed, holding (1) Defendant was not represented by counsel during his testimony; and (2) Defendant was entitled to a new trial because he did not voluntarily relinquish his right to counsel. Remanded for a new trial. View "State v. Francis" on Justia Law

After a jury trial, Defendant was found guilty of attempt to commit robbery in the first degree in violation of Conn. Gen. Stat. 53a-49(a)(2) and 53a-134(a)(3). Defendant appealed, arguing that the State was required to prove as an element of the crime of robbery in the first degree that he did not own the property that he had been convicted of attempting to take from the complainant and that the State did not do so. The Appellate Court reversed, concluding that the State had the burden of disproving that Defendant owned the property and that it had failed to meet this burden. The Supreme Court affirmed, holding that the Appellate Court correctly held that the State was required to prove that Defendant did not own the property that he attempted to take from another as an element of the crime of attempt to commit robbery in the first degree. View "State v. Smith" on Justia Law

After a jury trial, Defendant was found guilty of attempt to commit murder in violation of the attendant circumstances subdivision, rather than substantial step subdivision. See Conn. Gen. Stat. 53a-49(a)(1) and (2). Defendant appealed, arguing that the trial court erred in denying his motion for a judgment of acquittal because the State failed to prove beyond a reasonable doubt that Defendant had attempted the commit the murder under the attendant circumstances division. The Supreme Court affirmed, holding that the State presented sufficient evidence for a reasonable jury to find beyond a reasonable doubt that Defendant was guilty of attempt to commit murder in violation of Conn. Gen. Stat. 53a-54a(1) and the attendant circumstances subdivision of section 53a-49(a)(1). View "State v. Moreno-Hernandez" on Justia Law