Justia Connecticut Supreme Court Opinion Summaries

Petitioner entered a plea of nolo contendere to felony murder and related crimes. Petitioner was sixteen years old when he committed the crimes. The trial court sentenced Petitioner to a total effective prison term of fifty years with no possibility of parole. After Petitioner’s conviction and sentence became final, the U.S. Supreme Court decided Miller v. Alabama. Petitioner filed a petition for a writ of habeas corpus arguing that the statutory authority under which his fifty year prison term with no possibility of parole was imposed violated the Eighth Amendment as applied to him. The habeas court granted summary judgment for the State, concluding that Miller did not apply to Petitioner’s sentence. The Supreme Court reversed, holding (1) Miller applies retroactively under Connecticut law to cases arising on collateral review; and (2) Miller applies to the imposition of a fifty year sentence on a juvenile offender. Remanded. View "Casiano v. Comm’r of Corr." on Justia Law

After a jury trial, Defendant was convicted of murder and tampering with physical evidence. Defendant appealed, arguing that the trial court erred in failing to suppress (1) certain oral statements made to police officers after his apprehension on the ground that the statements were the result of a custodial interrogation without his having been read his Miranda warnings, and (2) a statement he made after being given his Miranda warnings on the ground that it was the product of coercion. The Supreme Court affirmed, holding that the trial court properly denied Defendant’s motion to suppress, as (1) Defendant was not subjected to custodial interrogation before receiving the Miranda warnings; and (2) Defendant’s confession was made voluntarily. View "State v. Ramos" on Justia Law

After a jury trial, Defendant was convicted of carrying a pistol without a permit, having a weapon in a motor vehicle with a permit, and possession of an assault weapon. The Appellate Court affirmed. Defendant appealed, arguing that the Appellate Court erred in concluding that the trial court properly rejected Defendant’s claim under Conn. Gen. Stat. 54-1c that he was entitled to the suppression of his written confession that he had given to the police following his arrest because he was not presented to the first session of the court. The Supreme Court affirmed, holding (1) section 54-1c did not bar the State’s use of Defendant’s written statement because section 54-1c is inapplicable when, as in this case, the statement is elicited prior to the expiration of the first session of court, when the defendant’s presentment still would have been timely; and (2) the evidence was sufficient to establish that Defendant had carried a pistol in violation of Conn. Gen. Stat. 29-35(a). View "State v. Crespo" on Justia Law

After a jury trial, Petitioner was found guilty of murder and carrying a pistol without a permit. The Appellate Court affirmed on direct appeal. Thereafter, Petitioner collaterally attacked his conviction by filing a petition for a writ of habeas corpus, claiming that his trial attorney had rendered ineffective assistance of counsel. The habeas court denied the habeas petition. On appeal, Petitioner raised for the first time a new theory as to why his attorney had rendered ineffective assistance. The Appellate Court declined to review Petitioner’s claim on the grounds that that review under State v. Golding is not available for unpreserved claims of error raised for the first time in a habeas appeal. The Supreme Court affirmed, holding that Golding review was unavailable for Petitioner’s ineffective assistance claim because that claim did not arise out of the actions or omissions of the habeas court itself. View "Moye v. Comm’r of Corr." on Justia Law

After a jury trial, Defendant was convicted of, among other crimes, intentional assault in the first degree and reckless assault in the first degree. The intentional and reckless assault in the first degree convictions were based on the same conduct. the Supreme Court affirmed, holding (1) Defendant’s convictions for intentional and reckless assault in the first degree were not legally inconsistent because the two mental states required to commit the offenses related to different results; and (2) the evidence was sufficient to support Defendant’s conviction of intentional assault in the first degree. View "State v. Nash" on Justia Law

After a jury trial, Defendant was convicted of possession of narcotics with intent to sell within 1500 feet of a public housing project and other narcotics and firearm charges. The Appellate Court reversed in part and remanded for a new trial, holding (1) the trial court improperly instructed the jury on the possession charge; and (2) the evidence presented at trial was sufficient to prove beyond a reasonable doubt that Defendant intended to sell narcotics within 1500 feet of a public housing project. The Supreme Court reversed in part, holding that the evidence adduced at trial was not sufficient to satisfy the State’s burden of proving beyond a reasonable doubt that Defendant intended to sell narcotics at a particular location within 1500 feet of a public housing project. View "State v. Stovall" on Justia Law

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