Justia Connecticut Supreme Court Opinion Summaries

Articles Posted in Criminal 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
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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

Posted in: Criminal Law
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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

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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

Posted in: Criminal Law