Justia Connecticut Supreme Court Opinion Summaries

Articles Posted in Criminal Law
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Defendant was convicted of sixteen federal felony offenses arising from actions he took while acting as the mayor of Bridgeport. After his release from prison, Defendant applied for reinstatement to the bar. The local standing committee issued a report in which it concluded that Defendant was fit to practice law and recommended that he be reinstated. The trial court denied Defendant’s application, concluding that the record did not substantiate a finding of good moral character and fitness to practice law. The Supreme Court affirmed, holding that the trial court properly concluded that the standing committee abused its discretion when it determined that Defendant was presently fit to practice law and recommended his reinstatement.View "State Grievance Comm. v. Ganim" on Justia Law

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After a jury trial, Defendant was convicted of manslaughter in the first degree with a firearm as an accessory, among other crimes. The convictions arose from a shooting that occurred during an altercation in a housing complex. The appellate court reversed the manslaughter conviction, concluding that insufficient evidence supported the conclusion that Defendant acted as an accessory by intentionally aiding Donald Wilson, the person who fired the fatal shots. The Supreme Court affirmed, holding that the record contained insufficient evidence to prove that Defendant assisted Wilson in the commission of the homicide.View "State v. Gonzalez" on Justia Law

Posted in: Criminal Law
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After a jury trial, Defendant was found guilty of four counts of sexual assault in the first degree and four counts of risk of injury to a child. Defendant appealed, arguing that the trial court erred in (1) permitting the state to use a video recording of a forensic interview of the child victim for substantive purposes, and (2) giving a certain jury instruction. The appellate court affirmed, holding (1) the trial court reasonably concluded the video recording of the child victim’s interview was admissible, and (2) Defendant implicitly waived his right to raise his second claim. The Supreme Court affirmed, holding (1) the appellate court correctly concluded that the trial court did not abuse its discretion in admitting the video recording into evidence; and (2) assuming, without deciding, that Defendant’s claim of instructional impropriety was not implicitly waived, the instruction did not deprive Defendant of a fair trial. View "State v. Carrion" on Justia Law

Posted in: Criminal Law
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After a jury trial, Defendant was convicted of murder. The Supreme Court affirmed the judgment of conviction, holding (1) the trial court properly denied Defendant’s motion to suppress pretrial and in-court identifications of Defendant; (2) the trial court acted within its discretion when it denied Defendant’s motion to have the jury view the scene of the crime; (3) the state met its burden of disproving Defendant’s justification of self-defense; and (4) the trial court did not commit plain error in its charge to the jury on Defendant’s claim of self-defense when it defined an “initial aggressor” as a person who appeared to threaten the imminent use of physical force. View "State v. Revels" on Justia Law

Posted in: Criminal Law
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In connection with his charge of interfering with an officer, Defendant applied for, and was accepted into, an accelerated rehabilitation program. After the expiration of his probationary period in the program, Defendant moved to dismiss the charge of interfering with an officer. The trial court denied the motion, finding that Defendant failed to satisfactorily complete the program because he was convicted of several unrelated crimes while participating in the program. Defendant appealed, arguing that the trial court did not have the discretion to consider the convictions because the conduct underlying the convictions took place before he was admitted into the program. The Supreme Court affirmed, holding that the purpose of the accelerated rehabilitation statute is to grant onetime offenders an opportunity to maintain a clean criminal record, and therefore, a conviction obtained while participating in the program is contrary to the purpose of the statute and requires a finding of unsatisfactory completion. View "State v. Kevalis" on Justia Law

Posted in: Criminal Law
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After a jury trial, Defendant was convicted of one count of sexual assault in the fourth degree. During trial, in seeking to imply that the complainant had a motive to testify favorably for the State, Defendant sought to question the complainant on recross-examination about the conditions of her participation in a pretrial diversionary program on a felony charge pending against her in an unrelated case. The trial court concluded that the prejudicial effect of the proffered evidence was greater than its probative value. The Appellate Court reversed the conviction, concluding that the trial court violated Defendant’s right to confrontation by precluding Defendant from eliciting such evidence. The Supreme Court reversed, holding that Defendant failed to establish a sufficient nexus between the testimony he sought to obtain and the complainant’s motive to testify favorably for the State to implicate his right to confrontation. View "State v. Benedict" on Justia Law

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Defendant was charged with one count of murder and related crimes for his role in the shooting death of Aaron McCrea. At trial, Defendant sought to introduce witness statements contained in a search warrant affidavit that purportedly implicated other individuals in the shooting. The trial court sustained the State’s objection, concluding that the statements constituted inadmissible hearsay. Defendant was subsequently convicted of all charges. Defendant appealed, arguing that he functionally preserved his claim that the statements in the search warrant affidavit should have been admitted under one of the hearsay exceptions and, in the alternative, his claim should be reviewed pursuant to State v. Golding. The Supreme Court rejected both of Defendant’s arguments, holding (1) Defendant failed to preserve his claim, functionally or otherwise; and (2) the claim was not of a constitutional nature such that review was warranted pursuant to Golding. View "State v. Santana" on Justia Law

Posted in: Criminal Law
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Defendant’s conviction for threatening in the second degree and breach of the peace in the second degree arose out of statements he made to an attorney that represented the Town of Waterford in a zoning dispute with Defendant. On appeal, Defendant argued that his statements were protected by the First Amendment to the Federal Constitution because they were not real or true threats. The Appellate Court affirmed. The Supreme Court reversed, holding that Defendant was entitled to a judgment of acquittal on both charges, as Defendant’s statements did not rise to the level of a true threat and were therefore entitled to the protection of the First Amendment despite their inflammatory nature. View "State v. Krijger" on Justia Law

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After a jury trial, Petitioner was convicted of sexual assault in the first degree and risk of injury to a child. The Appellate Court affirmed the convictions on direct appeal. Petitioner later sought habeas relief, claiming that his appellate counsel provided ineffective assistance by failing to investigate Petitioner’s claims that he had a history of sexually transmitted diseases and to introduce evidence concerning whether the victim had contracted any such diseases. The habeas court rejected Petitioner’s claim. The Appellate Court affirmed. The Supreme Court affirmed, holding that Petitioner failed to demonstrate that he was prejudiced by any deficiency in counsel’s performance. View "Anderson v. Comm’r of Corr." on Justia Law

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After a jury trial, Defendant was found guilty of two drug-related offenses following a police investigation that culminated in the seizure of heroin from defendant’s home pursuant to a search warrant. Defendant appealed, arguing, among other things, that the trial court erred in denying her motion to suppress certain statements because the statements had been obtained when a police officer interrogated her during the execution of the search warrant without first advising her in accordance with Miranda v. Arizona. The appellate court affirmed the convictions, determining that, at the time of the police questioning, Defendant was not in custody for purposes of Miranda, and therefore, Miranda warnings were not required. The Supreme Court reversed, holding (1) Defendant was in custody when she was questioned by the police officer, and, as a result, the police were required to advise her of her rights under Miranda; and (2) the Miranda violation was not harmless beyond a reasonable doubt.View "State v. Mangual" on Justia Law