Justia Connecticut Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of carrying a pistol without a permit and criminal possession of a firearm. Defendant was found not guilty of murder, either as a principal or an accessory. The Supreme Court affirmed the judgment of the trial court, holding (1) the trial court properly admitted testimony that Defendant previously had possessed a pistol on an occasion prior to the date of the crimes with which he was charged; and (2) the trial court did not abuse its discretion by considering, in sentencing Defendant, remarks made by the family of the victim in their impact statement and other evidence related to the murder charge, of which Defendant was found not guilty. View "State v. Pena" on Justia Law

Defendant was charged with, inter alia, six counts of capital felony in connection with a triple murder, sexual assault, and arson. During the trial, the trial court granted the motion of intervenors, a newspaper and one of its reporters, to vacate an order sealing Defendant's "witness list." The appellate court dismissed Defendant's appeal of the trial court decision for lack of a final judgment. The Supreme Court granted Defendant's petition for certification to appeal, (1) concluding that the appeal should be treated as a late petition for certification to appeal and, therefore, not determining whether the appellate court properly concluded the trial court's decision was not a final judgment; and (2) reversing the trial court's order granting the intervenors' motion to vacate the sealing order, holding that Defendant demonstrated that the potential abridgement of his rights to a fair trial and to prepare a defense clearly outweighed the rights of the intervenors and the public to access the witness list document. View "State v. Komisarjevsky" on Justia Law

After Defendant was charged in three criminal cases and, in a fourth case, with violating his probation, he was found incompetent to stand trial and not restorable to competency. Defendant filed a motion to dismiss the charges in all four cases, claiming (1) he was entitled to dismissal of two cases involving misdemeanor charges and the violation of probation case because the statute of limitations had expired, and (2) he was entitled to dismissal of the case involving a felony charge pursuant to Practice Book 41-8. The trial court granted the motion to dismiss with respect to all four of the pending cases on the ground that it lacked personal jurisdiction over Defendant. The Supreme Court (1) affirmed the trial court's judgment dismissing the two cases involving misdemeanor charges on the alternate ground that the charges were subject to dismissal pursuant to section 54-56d(m) because the statute of limitations had expired; (2) reversed the judgment of dismissal as to the felony charge and remanded for a determination as to whether the case should be dismissed pursuant to Practice Book 41-8(5); and (3) dismissed the portion of the appeal regarding the dismissal of the violation of the probation case. View "State v. Johnson" on Justia Law

At age fifteen, Defendant was charged with larceny in the second and fourth degrees and burglary in the third degree. Before the juvenile court, the State filed a motion to transfer the charges from the juvenile docket to the regular criminal docket pursuant to Conn. Gen. Stat. 46b-127(b). The juvenile court denied the State's motion. After the State filed an appeal, the Supreme Court released its decision in State v. Fernandes, which interpreted section 46b-127(b) to comply with due process requirements because, prior to the finalization of the transfer of a case involving certain crimes from the juvenile docket to the regular criminal docket, the juvenile is entitled to a hearing in the criminal court to contest the appropriateness of trying the juvenile as an adult. On appeal, the Supreme Court reversed the juvenile court's denial of the State's motion to transfer the charges of larceny in the second degree and burglary in the third degree and affirmed in all other respects, holding (1) Fernandes controlled in this case, and (2) before the transfer of Defendant's case to the regular criminal docket was finalized, Defendant was entitled to a hearing before the court on the regular criminal docket. Remanded. View "State v. Elias G." on Justia Law

Defendant was charged and convicted of murder, carrying a pistol without a permit, and criminal possession of a pistol. At trial, three witnesses who had criminal matters pending in a variety of venues testified that they had seen Defendant commit the murder. On appeal, Defendant claimed (1) the trial court committed plain error when it failed to instruct the jury, sua sponte, that the testimony of the three witnesses should be viewed with great caution in light of potential benefits the witnesses could receive from the government in their pending criminal matters in exchange for their testimony; and (2) in the alternative, the Supreme Court should exercise its supervisory power to require such an instruction. The Supreme Court affirmed the judgment of conviction, holding (1) the trial court did not commit plain error when it failed to give, sua sponte, a special credibility instruction for the three witnesses; and (2) because trial courts already have discretion to give a special credibility instruction under existing case law whenever the court reasonably believes a witness' testimony may be particularly unreliable, there is no need for the Court to create a new supervisory rule requiring a special credibility instruction in such cases. View "State v. Diaz" on Justia Law

After a jury trial, Harry Gonzalez was convicted of felony murder, robbery in the first degree, and kidnapping in the first degree. On appeal, the Supreme Court reversed the judgment of the trial court, holding (1) the trial court improperly denied in part Gonzalez's motion to suppress certain statements he had made to the police because he made those statements as a result of police interrogation while in custody and without having been informed of his Miranda rights, and the error was not harmless beyond a reasonable doubt; and (2) Gonzalez's constitutional right against double jeopardy was not violated by his convictions of and separate punishments for felony murder and first degree robbery. Remanded for a new trial. View "State v. Gonzalez" on Justia Law

After a jury trial, Defendant was convicted of two counts of kidnapping in the second degree and one count of risk of injury to a child. The Supreme Court reversed the judgment of the trial court as to one of the two kidnapping counts and remanded for a new trial on that charge, holding (1) Defendant was entitled to a jury instruction in accordance with State v. Salamon, which bars a jury from finding a defendant guilty of kidnapping if it finds that the restraint used in connection therewith was merely incidental to the restraint used in the commission of another offense, and (2) the trial court's failure to give such an instruction was not harmless beyond a reasonable doubt. The Supreme Court affirmed the trial court's judgment in all other respects. View "State v. Fields" on Justia Law

After a jury trial, defendant Oles Baptiste was convicted of assault of a peace officer and interfering with an officer. Defendant appealed, claiming that the trial court's jury instructions on the charges deprived him of his right to a fair trial and to present a defense. The appellate court affirmed, concluding that Defendant waived any constitutional or plain error claim by not raising an objection in the lower court proceedings. On appeal, Defendant claimed that the appellate court erred in concluding that he waived his claim of instructional error under State v. Kitchens, asserting that he did not have a meaningful opportunity for review of the jury instructions because the trial court held only a brief charging conference and Defendant did not receive a written copy of the instructions. The Supreme Court reversed the judgment of the appellate court, holding that because Defendant did not have a meaningful opportunity to review the charges, Defendant's claim was not implicitly waived under Kitchens. Remanded. View "State v. Baptiste" on Justia Law

After a police officer received frantic telephone calls by a concerned parent about his missing teenage son and the parent suggested that his son might be at the home of defendant Gary Ryder, the officer conducted a warrantless search of Ryder's home. During the search, the officer found a large reptile in Ryder's tub. Ryder was charged with risk of injury to a child and illegal possession of a reptile. The State entered a nolle prosequi with regard to the first charge, and Ryder entered a plea of nolo contendere to the possession of a reptile charge, later paying a fine. Ryder appealed from the trial court's denial of his motions to suppress and to dismiss the charges. Ultimately, the appellate court affirmed, concluding that the emergency exception to the warrant requirement justified the officer's entry into Ryder's home. On appeal, the Supreme Court reversed the judgment of the appellate court, holding that the emergency exception to the warrant requirement did not justify the warrantless search of Ryder's curtilage and the subsequent warrantless search of Ryder's home. Remanded. View "State v. Ryder" on Justia Law

After a jury trial, Defendant Thomas W. was convicted of risk of injury to a child and sexual assault in the fourth degree. On appeal, Defendant contended that the trial court improperly diluted the State's burden of proof and placed the burden of proof on Defendant by instructing the jurors that they must decide whether Defendant was "innocent or guilty" of the crimes for which he was charged. The appellate court declined to review Defendant's claim on the ground of waiver, concluding that Defendant waived his claim of instructional error. The Supreme Court granted certification. At issue was whether Defendant could be deemed to have waived his objection to certain language in the final instructions to the jury when, after a charging conference and other procedures consistent with the standard set forth in State v. Kitchens, Defendant did not object to that language but previously had objected to essentially the same language in the trial court's preliminary instructions to the jury. The Supreme Court affirmed the appellate court's judgment, holding that, under the facts of the case, Defendant waived his claim under the general rule enunciated in Kitchens. View "State v. Thomas W." on Justia Law