Justia Connecticut Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of conspiracy to sell narcotics by a person who is not drug-dependent and interfering with an officer. The appellate court affirmed. On appeal, Defendant argued, among other things, that the appellate court abused its discretion by refusing to adopt the buyer-seller exception applied by federal courts in evaluating the sufficiency of the evidence of conspiracy to sell narcotics. The Supreme Court affirmed, holding (1) the considerations embodied in the buyer-seller exception are already reflected in the laws of the state; and (2) the evidence demonstrated more than a mere buyer-seller relationship with Defendant’s coconspirator on a single occasion, and therefore, the evidence was sufficient to support Defendant’s conspiracy conviction. View "State v. Allan" on Justia Law

In 1993, Defendant was convicted of several offenses. Defendant also pleaded guilty to being a persistent dangerous felony offender and to being a persistent serious felony offender. Judge Espinosa sentenced Defendant to an enhanced sentence. In 2008, Defendant filed a motion to correct an illegal sentence, claiming that he was constitutionally entitled to have a jury determine whether extended incarceration would be in the public interest. The trial court dismissed the motion. Defendant subsequently filed a second motion to correct an illegal sentence, claiming that Judge Espinosa had failed to make the required finding that an enhanced sentence would best serve the public interest. The trial court denied the motion, concluding that Defendant’s claim was barred by the doctrine of res judicata. The Supreme Court affirmed the trial court’s judgment on the alternative ground that Judge Espinosa made the necessary finding that imposing an enhanced sentence on Defendant would best serve the public interest. View "State v. Henderson" on Justia Law

Under the apparent authority doctrine recognized by the United States Supreme Court, a warrantless entry is valid when based upon the consent of a third party whom the police, at the time of the entry, reasonably believe to possess common authority over the premises, but who in fact does not have such authority. The trial court in this case denied Defendant’s motion to suppress evidence obtained after law enforcement’s warrantless entry of Defendant’s apartment based on the apparent authority doctrine. After a jury trial, Defendant was convicted. On appeal, Defendant contended that although the apparent authority doctrine is recognized as an exception to the warrant requirement under the federal constitution, it is inconsistent with Conn. Const. art. I, 7. The Appellate Court concluded that application of the doctrine does not offend the right of Connecticut citizens to be free from unreasonable searches under article first, section 7. The Supreme Court affirmed, holding that the Appellate Court’s opinion was a proper statement of the applicable law on this issue. View "State v. Buie" on Justia Law

At issue in this criminal case was whether Conn. Gen. Stat. 53a-151(a), which proscribes tampering with a witness, requires the intent to influence a witness’ conduct at an official proceeding. After a jury trial, Defendant was convicted of tampering with a witness. The Appellate Court affirmed. Defendant argued on appeal that section 53a-151(a) does not prohibit mere attempts to prevent an individual from speaking to the police. The Supreme Court affirmed Defendant’s conviction, holding (1) the statute requires the intent to affect a witness’ conduct at an official proceeding, but a jury may infer this intent from the defendant’s attempt to prevent an individual from giving a statement to the police; and (2) there was sufficient evidence in this case indicating that Defendant believed an official proceeding was about to be instituted and that he threatened an individual with the intent to induce her to withhold testimony at a criminal trial. View "State v. Ortiz" on Justia Law

At issue in this certified appeal was the extent of a law enforcement agency’s disclosure obligations under the Freedom of Information Act (Act) with respect to pending criminal investigations. In 1993, the Supreme Court decided Gifford v. Freedom of Information Commission, which held that the police’s disclosure obligations during a pending criminal investigation were governed by the statutory predecessor to Conn. Gen. Stat. 1-215, which required a law enforcement agency to release only police blotter information. The legislature subsequently enacted Public Acts 1994, No. 94-246, 13, which amended the statutory predecessor to section 1-215 to require broader disclosure. In the instant case, the Freedom of Information Commission (Commission) found that the Department of Public Safety (Department) violated the Act by failing to disclose certain records from a pending criminal case. The trial court sustained the Department’s administrative appeal, and the Appellate Court affirmed. The Supreme Court affirmed, holding the enactment of Public Act 94-246 did not legislatively overrule the Court’s conclusion in Gifford that, during pending criminal prosecutions, section 1-215 exclusively governs law enforcement agencies’ disclosure obligations under the Act. View "Comm’r of Pub. Safety v. Freedom of Info. Comm’n" on Justia Law

Defendant was arrested without a warrant and charged with several crimes. Defendant filed a motion to be released without bond because a probable cause finding had not been made within forty-eight hours of his arrest. The trial court denied Defendant's motion. The appellate court upheld the trial court's decision. The Supreme Court affirmed, holding that, under the specific facts of this case, any violation of Defendant's Fourth Amendment rights was de minimis where (1) Defendant was present in the courthouse awaiting arraignment, at which point probable cause findings are typically made, prior to the expiration of the forty-eight hour period; and (2) the trial court found probable case for Defendant's arrest less than two hours after expiration of the forty-eight hour time period.View "State v. Heredia" on Justia Law

Defendant was convicted of multiple offenses and sentenced to a term of incarceration followed by sixteen years of special parole. Defendant filed a motion to correct an illegal sentence, arguing that the trial court illegally sentenced him to a sixteen year term of special parole when, in light of the crimes at issue, the maximum terms of special parole was ten years. The trial court denied the motion. The appellate court reversed, concluding that the two consecutive sentences of special parole at issue - neither of which exceeded ten years individually but together imposed a total effective sentence of sixteen years of special parole - violated Conn. Gen. Stat. 54-125e(c), which operates as an aggregate limitation on the total effective sentence of special parole when a defendant is sentenced for multiple offenses. The Supreme Court reversed, holding that the ten year limitation on a period of special parole provided for in section 54-125e(c) applies per offense, rather than to the total effective sentence of special parole. Remanded. View "State v. Brown" on Justia Law

After a jury trial, Defendant was convicted of sexual assault in a spousal relationship in violation of Conn. Gen. Stat. 53a-70b. Defendant appealed, claiming that the trial court should interpret section 53a-70b to require proof beyond a reasonable doubt that Defendant acted with the specific intent to commit the crime of sexual assault in a spousal relationship. The appellate court rejected the claim and affirmed. The Supreme Court affirmed, holding that the appellate court properly concluded that section 53a-70b requires that Defendant had only a general intent to commit the act that constituted a violation of the statute.View "State v. Ferdinand R." on Justia Law

After a jury trial, Petitioner was convicted of several offenses in connection with an incident involving Petitioner’s estranged girlfriend. Petitioner later filed a second amended petition for a writ of habeas corpus, claiming that his trial counsel provided ineffective assistance. Specifically, Petitioner alleged that his counsel’s criminal prosecution shortly before Petitioner’s criminal trial constituted a conflict of interest. The habeas court denied Petitioner’s petition. The appellate court affirmed, concluding that Petitioner’s claim failed on the merits. At issue before the Supreme Court was whether there was a constitutionally impermissible risk that a jury would attribute the conduct of Petitioner’s trial counsel to Petitioner when his counsel had been acquitted of a dissimilar crime in the same judicial district in which Petitioner faced criminal prosecution. The Supreme Court affirmed, holding that Petitioner failed to demonstrate an actual conflict of interest that adversely affected his trial counsel’s performance. View "Rodriguez v. Comm’r of Corr." on Justia Law

Petitioner was charged with various criminal offenses in two informations. After a jury trial, Petitioner was convicted of sexual assault in the second degree, assault in the second and third degrees, and risk of injury to a child. After the convictions were affirmed on appeal, Petitioner filed a petition for a writ of habeas corpus, alleging ineffective assistance of counsel. The habeas court found Petitioner's pretrial counsel had rendered ineffective assistance by failing to provide Petitioner with adequate advice regarding a pretrial plea offer and ordered the trial court to resentence Petitioner in accordance with the sentence proposed in the plea offer. The appellate court affirmed. The Supreme Court reversed, holding that the habeas court improperly circumvented the trial court's discretion to impose an appropriate sentence. Remanded.View "H.P.T. v. Comm'r of Corr." on Justia Law