Justia Connecticut Supreme Court Opinion Summaries

Articles Posted in Criminal Law
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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. Although only Defendant’s accomplice was armed during the commission of the robbery, the trial court sentenced Defendant to an enhanced sentence pursuant to Conn. Gen. Stat. 53-202k, which provides for a mandatory prison term when a person uses, or is armed with and threatens to use, a firearm in the commission of a felony. Defendant appealed, arguing that the Supreme Court should either overrule its holding in State v. Davis that section 53-202k applies to unarmed accomplices or limit the applicability of section 53-202k to unarmed accomplices who intend that a firearm be used in the commission of the underlying offense. The Supreme Court affirmed the judgment of the trial court, holding (1) there are several reasons to decline Defendant’s invitation to overrule or otherwise limit Davis; and (2) in light of Davis, the state was not required to also prove that Defendant intended that a firearm would be used during the robbery. View "State v. Flemke" on Justia Law

Posted in: Criminal Law
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After a jury trial, Defendant was found guilty of conspiracy to commit robbery in the second degree in violation of Conn. Gen. Stat. 53a-48(a). Defendant appealed, arguing that the trial court erred by failing to instruct the jury that, to find Defendant guilty of the conspiracy charge, it must find that he had specifically intended that the planned robbery would involve the display or threatened use of what was represented to be a deadly weapon or dangerous instrument. The Appellate Court agreed with Defendant and reversed. The Supreme Court affirmed, holding that, to be convicted of conspiracy to commit robbery in the second degree, a defendant must specifically intend that there would be the display or threatened use of what was represented as a deadly weapon or dangerous object during the robbery or immediate flight therefrom. View "State v. Pond" on Justia Law

Posted in: Criminal Law
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Petitioner, an inmate at McDougall Correctional Institution, was found guilty of possession of contraband. After a hearing at which Petitioner was permitted to present witnesses and to testify on his own behalf, the Inmate Classification Administrator, ordered that Petitioner be placed in administrative segregation at Northern Correctional Institution, the state’s maximum security prison. Petitioner subsequently filed a habeas petition, which the habeas corpus denied. Petitioner appealed, arguing that the habeas court abused its discretion because it did not address his contention that his placement in administrative segregation violated his right to due process. The Appellate Court rejected Petitioner’s claims. The Supreme Court affirmed, holding (1) the Appellate Court incorrectly indicated that Connecticut prisoners can never establish a liberty interest in avoiding administrative segregation; (2) the Appellate Court incorrectly determined that the habeas court acted within its discretion in denying the petition for certification to appeal from the judgment of the habeas court because the habeas court’s reason for denying that petition was unsupportable; but (3) even if Petitioner had a liberty interest in avoiding his transfer to Northern, he received all of the process he was due prior to that transfer. View "Vandever v. Comm’r of Corr." on Justia Law

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After a jury trial, Defendant was convicted of burglary in the first degree and kidnapping in the first degree. The Appellate Court vacated Defendant’s conviction and ordered a hearing to determine whether a competency evaluation was required, determining that the trial court had violated Defendant’s right to due process by failing to conduct a proper inquiry into Defendant’s competency. The Supreme Court affirmed, holding (1) the Appellate Court properly determined that the trial court’s independent inquiry into Defendant’s request for a competency evaluation was inadequate; (2) under the specific facts of this case, it was an abuse of the trial court’s discretion not to order a competency hearing; and (3) the remedy ordered by the Appellate Court was in line with United States Supreme Court precedent. Remanded. View "State v. Dort" on Justia Law

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Defendant, who had an extensive weapons collection, was transporting a dirk knife, police baton and other weapons from his former residence in Connecticut to his new residence in Massachusetts when he was involved in a traffic accident. The State subsequently charged Defendant with six counts of having a weapon in a motor vehicle in violation of Conn. Gen. Stat. 29-38(a). A jury found Defendant guilty of two counts. The Supreme Court reversed, holding that the current statutory scheme, which categorically bars the transportation of a dirk knife and police baton by motor vehicle from a former residence to a new residence, impermissibly infringes on a person’s constitutional right under the second amendment to possess those weapons. View "State v. DeCiccio" on Justia Law

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After a jury trial, Defendant was convicted of two counts of risk of injury to a child. The Appellate Court affirmed. The Supreme Court affirmed, holding (1) Defendant’s claim of error in the admission of out-of-court statements of one of the victims through the testimony of a police officer to provide context for Defendant’s admission to the conduct underlying the charges against him was not properly preserved; (2) even assuming that certain out-of-court statements of one of the victims that were admitted through the testimony of the state’s expert as examples of their age inappropriate knowledge were improperly admitted, any impropriety was harmless; and (3) Defendant was not deprived of a fair trial by any purported prosecutorial impropriety. View "State v. Paul B." on Justia Law

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After a jury trial, Defendant was convicted of one count of intentional manslaughter in the first degree with a firearm. Defendant appealed, arguing, among other things, that his conviction violated his constitutionally protected right against double jeopardy because a reasonable possibility existed that he was acquitted of the offense at an earlier trial. The Supreme Court affirmed, holding (1) Defendant’s conviction did not violate right against double jeopardy; and (2) any error committed by the trial court in construing the term “crime of violence” and in instructing the jury on the elements of the various offenses that fall within the definition of “crime of violence” was harmless beyond a reasonable doubt. View "State v. Terwilliger" on Justia Law

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After a jury trial, Petitioner was found guilty of murder, conspiracy to commit murder, and larceny in the first degree. The Appellate Court affirmed the judgment. Nearly nine years later, Petitioner filed an amended petition for writ of habeas corpus alleging that he received ineffective assistance of counsel at trial because his counsel failed to call two witnesses whose testimony would have contradicted that of an important state’s witness regarding Petitioner’s motive to commit the offenses for which he was found guilty. The habeas court denied the petition and, further, denied Petitioner’s request for certification to appeal. The Appellate Court dismissed Petitioner’s appeal. The Supreme Court affirmed, holding that assuming, without deciding, that the habeas court’s denial of certification was an abuse of discretion, Petitioner failed to demonstrate that he was entitled to a new trial. View "Sanchez v. Comm’r of Corr." on Justia Law

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After a jury trial, Defendant was convicted of burglary in the third degree and larceny in the second degree. The Appellate Court affirmed. The Supreme Court affirmed, holding that the Appellate Court did not err in concluding that (1) Public Acts 2009, No. 09-138, 2, which amended the second degree larceny statute to increase the value of property stolen necessary to constitute the offense, was not intended to be an ameliorative act that applied retroactively; and (2) the trial court did not abuse its discretion in admitting certain uncharged misconduct evidence concerning Defendant’s activities in another location. View "State v. Cote" on Justia Law

Posted in: Criminal Law
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After a jury trial, Defendant was convicted of burglary in the third degree and larceny in the second degree. The Appellate Court affirmed the judgment of conviction. The Supreme Court affirmed, holding that the Appellate Court did not err in concluding that (1) the trial court did not abuse its discretion in permitting the state to introduce evidence of Defendant’s uncharged misconduct to prove his intent to commit the charged crimes; and (2) Public Acts 2009, No. 09-138, 2, which amended the second degree larceny statute to increase the value of property stolen necessary to constitute the offense, does not apply retroactively. View "State v. Kalil" on Justia Law

Posted in: Criminal Law