Justia Connecticut Supreme Court Opinion Summaries

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

Defendant was charged with murder, among other crimes. Defendant, who was indigent, waived his right to appointed counsel and elected to represent himself. Defendant requested that the trial court order funding so that he could retain experts and an investigator in order to present a defense. The parties subsequently entered into a joint stipulation requesting the trial court to reserve questions of law to the Supreme Court regarding the funding issue. The Supreme Court answered (1) an indigent self-represented defendant is constitutionally entitled to expert or investigative services at public expense, provided that he makes a threshold showing that such assistance is reasonably necessary to formulate and present a defense; (2) the trial court does not retain the discretion to authorize public expenditures for any such expert witness or investigator; and (3) the public funds should come from the State’s Office of the Chief Public Defender. View "State v. Wang" on Justia Law

After a jury trial, Defendant was convicted of risk of injury to a child and sexual assault in the fourth degree. The Supreme Court reversed the trial court's judgment, holding (1) the prosecutor made improper statements during closing arguments and in connection with defense counsel's cross-examination of key state's witnesses, and the prosecutorial impropriety deprived Defendant of his due process right to a fair trial; and (2) the trial court improperly admitted into evidence a video recording and transcript of a forensic interview of the victim under the tender years exception to the hearsay rule without first conducting a hearing. Remanded for a new trial.View "State v. Maguire" on Justia Law

After a jury trial, Defendant was convicted of sexual assault in the first degree and risk of injury to a child. The Supreme Court reversed the judgment of the trial court and remanded for a new trial, holding (1) the trial court abused its discretion by improperly precluding Defendant from introducing, on relevancy grounds, evidence of prior sexual conduct that was admissible under the rape shield statute, in violation of Defendant’s federal and state constitutional rights to confrontation; and (2) the trial court’s preclusion of the evidence was not harmless beyond a reasonable doubt. View "State v. Shaw" on Justia Law