Justia Connecticut Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of assault in the first degree. On appeal, Defendant claimed, inter alia, that the trial court abused its discretion in admitting evidence of four of Defendant's prior felony convictions to impeach his credibility because the four felonies at issue were more than ten years old and “did not bear directly on his veracity.” The Appellate Court agreed with Defendant but concluded that the impropriety was harmless. The Supreme Court affirmed, holding that the Appellate Court properly determined that the admission of Defendant’s record of prior convictions constituted harmless error. View "State v. Clark" on Justia Law

After a jury trial, Defendant was found guilty of assault of public safety personnel. Defendant appealed, arguing that his rights to equal protection were violated, along with the same rights of a venireperson, C.D., who was excluded from the jury on the basis of C.D.’s answer to a question about race. Defendant further argued that the Supreme Court should exercise its supervisory authority to disallow peremptory challenges based on answers to the question about race in the juror questionnaire. The Supreme Court affirmed the judgment of the trial court, holding (1) the constitutional rights of Defendant and C.D. were not violated, as the prosecutor articulated a race neutral, nonpretextual explanation for his peremptory challenge; and (2) the Court declines to invoke its supervisory authority in the present case. View "State v. Edwards" on Justia Law

After a jury trial, Defendant was convicted of assault of public safety personnel and engaging police in pursuit. During trial, the trial court required the jury, if it chose to watch a digital video exhibit again during its deliberations, to view it in open court rather than providing the jury with the equipment needed to watch the video in the privacy of the jury room. The Appellate Court affirmed the convictions, concluding that this procedure complied with the mandate, set forth in Practice Book 42-23(a), that the trial court “shall submit” to the jury all exhibits received in evidence for review during its deliberations. The Supreme Court affirmed, holding that a trial court has discretion, pursuant to its inherent authority to manage the trial process, to determine the means by which the jury reviews submitted evidence during its deliberations, and therefore, the trial court did not abuse its discretion in this case. View "State v. Jones" on Justia Law

After a jury trial, Appellant was convicted of tampering with physical evidence in violation of Conn. Gen. Stat. 53a-155, attempt to commit robbery in the third degree, and conspiracy to commit robbery in the third degree. The Appellate Court affirmed. The Supreme Court affirmed in part and reversed in part, holding (1) the Appellate Court properly concluded that the prosecutor’s failure to correct potentially misleading testimony of two witnesses did not violate Appellant’s due process right to a fair trial; (2) the Court's prior construction of section 53a-155 in State v. Foreshaw is not overruled; and (3) under a proper understanding of Foreshaw, the evidence was not sufficient to support Appellant’s conviction for tampering with physical evidence in violation of 53a-155. Remanded. View "State v. Jordan" on Justia Law

After a jury trial, Defendant was convicted of criminal possession of a firearm. Defendant appealed, arguing that the trial court erred in denying his motion to suppress evidence obtained by law enforcement officers as a result of their warrantless entry into a bedroom where he was sleeping. The Appellate Court reversed, concluding that it was unreasonable for the police to assume that Defendant was present in the bedroom and posed an imminent threat of harm to the apartment’s occupants. The Supreme Court reversed, holding that, under the totality of the circumstances, the police officers reasonably believed that the warrantless entry into the bedroom was necessary to protect their own safety and the safety of others on the premises, and therefore, the entry did not violate Defendant’s Fourth Amendment rights. View "State v. Kendrick" on Justia Law

After a jury trial, Defendant was found guilty of accessory to assault in the first degree by means of a dangerous weapon. Defendant appealed, arguing that the trial court abused its discretion in denying his motion to suppress the victim’s out-of-court and in-court identifications of him as one of the victim’s assailants. The Appellate Court reversed, concluding that the admission of Defendant’s identifications following an unnecessarily suggestive procedure by the police violated Defendant’s constitutional rights, and the error was not harmless beyond a reasonable doubt. The Supreme Court reversed, holding (1) contrary to the Court’s holding in State v. Gordon, the improper admission of suggestive and unreliable identification is subject to harmless error analysis; and (2) assuming, without deciding, that the trial court erred in denying Defendant’s motion to suppress the victim’s identification testimony, the error was harmless. View "State v. Artis" on Justia Law

After a jury trial, Defendant was convicted of assault in the first degree by means of a dangerous weapon. On appeal, Defendant argued that the trial court abused its discretion in declining to admit evidence of an online conversation proffered by Defendant to impeach one of the state’s witnesses on the grounds that the document was inadmissible because it was improperly authenticated. The Appellate Court affirmed. The Supreme Court affirmed, holding that assuming, without deciding, that it was an abuse of discretion for the trial court to exclude the proffered evidence, the ruling was harmless. View "State v. Eleck" on Justia Law

After a jury trial, Defendant was convicted of two counts of unlawful restraint in the first degree. Defendant appealed, arguing that the prosecutor engaged in certain improprieties that deprived him of his due process right to a fair trial. The Appellate Court affirmed, holding that reversal of Defendant’s convictions was unwarranted. The Supreme Court affirmed, holding that, considering the alleged prosecutorial improprieties within the context of the entire trial, the instances of alleged prosecutorial impropriety identified by Defendant did not affect the fairness of the trial or prejudice Defendant under the standard set forth in State v. Williams. View "State v. Ciullo" on Justia Law

Upon responding to a 911 call from a tenant of a rooming house reporting a disturbance involving a gun, police officers entered an unlocked attic space in the house and retrieved marijuana and a gun. After a jury trial, Defendant, who resided in a room on the third floor of the house, was convicted of attempt to commit criminal possession of a firearm, criminal possession of a pistol, and possession of marijuana with intent to distribute. Defendant appealed the denial of his motion to suppress the evidence seized by the police as products of an unlawful search, claiming he had a reasonable expectation of privacy in the attic. The appellate court affirmed, holding that, because of Defendant’s lack of control over the access of others to the attic, Defendant did not have an expectation of privacy in that space that society would recognize as reasonable. The Supreme Court affirmed, holding that appellate court properly resolved the issue by virtue of its well-reasoned decision.View "State v. Pierre" on Justia Law

After a jury trial, Defendant was convicted of committing the crime of robbery in the first degree. In its information charging Defendant, the state alleged that Defendant was armed with a firearm during the commission of the crime. During trial, however, the court instructed the jury that Defendant could be found guilty if all other elements of the crime had been proven and if any person participating in the commission of the crime possessed a firearm. Defendant appealed, arguing that the trial court improperly instructed the jury that it could find him guilty under a theory of liability not set forth in the State’s information. Because Defendant did not preserve his claim for appellate review by objecting to the jury instruction, he sought review under State v. Golding. The appellate court declined to review Defendant’s claim on appeal, concluding that Defendant had implicitly waived any objection to the jury instructions under the rule set forth in State v. Kitchens. The Supreme Court reversed, holding that Defendant did not implicitly waive his claim because he was never provided with the court’s actual proposed charge and consequently did not have a meaningful opportunity to review the instructions.View "State v. Davis" on Justia Law