Justia Connecticut Supreme Court Opinion Summaries

After a jury trial, Petitioner was convicted of capital felony and arson murder, among other offenses. Petitioner sought a writ of habeas corpus alleging that his due process rights were violated because the State had failed to disclose a note written by a police detective containing details concerning the length of time that the fire burned inside the victim’s apartment prior to being discovered. First habeas counsel failed to pursue the claim, and consequently, the first habeas court rejected that claim as abandoned. Petitioner subsequently filed this habeas petition, alleging that the State withheld the evidence in violation of Brady v. Maryland and that his first habeas counsel had rendered ineffective assistance by failing to pursue and prove that claim. The second habeas court dismissed the claim. The Appellate Court remanded. The third habeas court rejected the petition. The Appellate Court reversed in part and remanded with direction to grant the petition for a writ of habeas corpus and for a new trial. The Supreme Court affirmed, holding that Petitioner was deprived of a fair trial because his rights under Brady were violated and that Petitioner’s first habeas counsel provided ineffective assistance by failing to establish that violation. View "Lapointe v. Comm’r of Corr." on Justia Law

Petitioner was convicted of possession of narcotics with intent to sell. Petitioner later filed an amended petition for writ of habeas corpus, arguing that his trial counsel rendered ineffective assistance by failing to advise him, pursuant to Padilla v. Kentucky, that his plea of guilty and subsequent conviction would constituted an aggravated felony under federal law and result in his almost certain deportation and permanent removal from the United States. After a trial, the habeas court granted the amended petition, concluding that Padilla applied retroactively to Petitioner’s guilty plea and that Petitioner was misadvised and prejudiced under Strickland v. Washington. The Supreme Court reversed, holding (1) Padilla does not apply retroactively to Petitioner’s guilty plea under federal law; and (2) Petitioner cannot prevail on alternative grounds. View "Thiersaint v. Comm’r of Corr." on Justia Law

Defendant was convicted of possession of narcotics, conspiracy to possess narcotics, conspiracy to possess narcotics with intent to sell, and other drug-related offenses. Defendant appealed, challenging her conviction on the three narcotics offenses. The Appellate Court reversed the conviction of conspiracy to possess narcotics on double jeopardy grounds but affirmed the judgment as to the remaining charges. Defendant appealed, arguing that the Appellate Court improperly concluded that she waived any appellate claim regarding structural error and seeking reversal of her conviction on the two remaining narcotics charges. The Supreme Court affirmed, holding that Appellate Court erred in determining that Defendant implicitly waived her instructional claims even though she had filed a request to charge for the instructions, but the error was harmless. View "State v. Johnson" on Justia Law

After a jury trial, Defendant was convicted of several drug-related offenses. The Appellate Court determined that Defendant’s convictions of the lesser included offense of conspiracy to possess narcotics and the greater offense of conspiracy to possess narcotics with intent to sell constituted a violation of the double jeopardy clause. The court vacated Defendant’s conviction for the lesser included offense. The court also vacated Defendant’s sentence for the greater offense and remanded for resentencing on that charge in accordance with the aggregate package theory. The Supreme Court reversed in part the judgment of the Appellate Court, holding that, although the trial court had the discretion to resentence Defendant, it was improper under the circumstances of this case for the Appellate Court to order the trial court to hold a resentencing hearing, as Defendant’s total effective sentence was not altered by the Appellate Court’s decision. View "State v. Johnson" on Justia Law

After a jury trial, Defendant was convicted of sexual assault in the first degree, sexual assault in the fourth degree, and risk of injury to a child. Defendant appealed, arguing that the prosecutor improperly commented on his right not to testify during her closing argument at trial. The Appellate Court affirmed. The Supreme Court affirmed, holding that the prosecutor did not engage in any impropriety and that her comments were within the constitutional limits prescribed by the Fifth Amendment. View "State v. Ruffin" on Justia Law

In 2009, Defendant pleaded guilty to two charges of possession of less than one-half ounce of marijuana. In 2011, during his probation period, Defendant was again charged with possession of less than one-half ounce of marijuana. Later that year, the legislature enacted No. 11-71 of the 2011 Public Acts (P.A. 11-71), which changed the penalty for possessing less than one-half ounce of marijuana from a potential term of imprisonment and/or a large fine to a small fine. Defendant subsequently petitioned for the destruction of the records of his two 2009 convictions pursuant to Conn. Gen. Stat. 54-142d, which allows for the erasure and destruction of records pertaining to a conviction that has later been decriminalized. The trial court denied relief. The Appellate Court affirmed, holding that, after the passage of P.A.11-71, the possession of less than one-half ounce of marijuana was not “decriminalized” within the meaning of section 54-142d. The Supreme Court reversed in part, holding that P.A. 11-71 decriminalized the possession of less than one-half ounce of marijuana for purposes of section 54-142d. View "State v. Menditto" on Justia Law

After a jury trial, Defendant was convicted of sexual assault in the first degree, sexual assault in the fourth degree, and risk of injury to a child. The Supreme Court affirmed, holding (1) even though Defendant was only fourteen and fifteen years old when he committed the crimes, the trial court did not err in imposing the mandatory minimum sentences for the first degree sexual assault conviction and the risk of injury conviction, as the mandatory minimum requirements left the trial court with broad discretion to fashion an appropriate sentence that accounted for Defendant’s youth and immaturity when he committed the crimes; (2) the state’s expert witness did not improperly vouch for the credibility of the victim; and (3) Defendant’s argument that the trial court improperly admitted evidence of sexual misconduct committed by Defendant when he was thirteen years old on propensity grounds was unpreserved for appeal. View "State v. Taylor G." on Justia Law

In Miller v. Alabama, the U.S. Supreme Court held that mandatory sentencing schemes that impose on juvenile offenders a term of life imprisonment without parole violate the Eighth Amendment. At issue in this case was whether a life sentence without parole may be imposed on a juvenile homicide offender in the exercise of the sentencing authority’s discretion. Defendant, who was seventeen years old at the time of the crimes leading to his convictions, was convicted of murder and other crimes. Defendant was sentenced to a total effective sentence of 100 years imprisonment, which was the functional equivalent to life without the possibility of parole. The Supreme Court reversed, holding (1) in considering whether to sentence a juvenile to a discretionary sentence of life imprisonment without the possibility of parole, the sentencer is required to take into account the factors that Miller deemed constitutionally significant before determining that such severe punishment is appropriate; and (2) in light of the uncertainty of Defendant’s sentence upon due consideration of the Miller factors, a new sentencing proceeding must be held that conforms with the dictates of Miller. View "State v. Riley" on Justia Law

After a jury trial, Defendant was convicted of one count of murder. On appeal, Defendant asserted that the trial court abused its discretion by (1) excusing a juror for injecting extraneous matters into deliberations and for refusing to deliberate; (2) excusing a second juror who was absent for one day without inquiring how long she would be unavailable; and (3) admitting into evidence testimony and a video recording relating to Defendant's refusal to cooperate with the police as they were taking a buccal swab from him. The Supreme Court affirmed, holding that the trial court did not abuse its discretion in (1) excusing the two jurors from the jury; (2) denying Defendant’s motions for a mistrial after the court excused the two jurors; and (3) admitting, as consciousness of guilt evidence, the testimony and video record of Defendant’s refusal to cooperate with the police. View "State v. Gonzalez" on Justia Law

After a jury trial, Defendant was found guilty of robbery in the first degree as an accessory and conspiracy to commit robbery in the first degree. The jury further found that a firearm had been used in the commission of the robbery, and therefore, the trial court concluded that Defendant was subject to a sentence enhancement under Conn. Gen. Stat. 53-202k, which provides for a mandatory term of imprisonment when a person uses, or is armed with and threatens to use, a firearm in the commission of a felony. Defendant was unarmed when the robbery occurred. On appeal, Defendant argued, among other things, that she was not subject to sentence enhancement under section 53-202k because that provision should be construed to apply only to persons who either use a firearm in the commission of the offense or intend that another participant in the offense do so. The Supreme Court affirmed, holding (1) the evidence was sufficient to support Defendant’s convictions; (2) in light of the Court’s decision in State v. Flemke, decided today, Defendant was subject to sentence enhancement under section 53-202k; and (3) the trial court properly instructed the jury regarding the state’s burden of proof. View "State v. Danforth" on Justia Law