Justia Connecticut Supreme Court Opinion Summaries

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

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