Justia Connecticut Supreme Court Opinion Summaries

In this companion case to Brown v. Commissioner of Correction, __ A.3d __ (2022), which the Court also decided today, the Supreme Court reversed the decision of the appellate court affirming the judgment of the habeas court dismissing Appellant's petition for a writ of habeas corpus pursuant to Practice Book 23-29 sua sponte and without prior notice, holding that remand was required.Petitioner filed a third petition for a writ of habeas corpus asserting four claims. The habeas court, sua sponte and without prior notice, dismissed the petition pursuant to Practice Book 23-29. The Supreme Court reversed, holding that because the habeas court did not have the benefit of the Court's decision in Gilchrist v. Commissioner of Correction, 223 A.3d 368 (Conn. 2020), remand was required for the habeas court to first determine whether any grounds exist for it to decline to issue the writ pursuant to Practice Book 23-24. View "Boria v. Commissioner of Correction" on Justia Law

The Supreme Court affirmed Defendant's conviction, rendered after a jury trial, of one count each of felony murder, conspiracy to commit robbery in the first degree, and carrying a pistol without a permit, holding that Defendant was not entitled to relief on his claims of error.Specifically, the Supreme Court held (1) under the circumstances of the case, the trial court did not abuse its discretion when it admitted a dual inculpatory statement under section 8-6(4) of the Connecticut Code of Evidence; (2) the statement at issue was non-testimonial, and its admission at trial did not violate Defendant's Sixth Amendment right to confrontation; (3) certain statements made by the prosecutor did not violate Defendant's right to confrontation under the state Constitution; and (4) Defendant was not entitled to relief on his second claim of impropriety. View "State v. Graham" on Justia Law

The Supreme Court affirmed Defendant's conviction of home invasion, burglary, and other crimes, holding that there was no error on the part of the trial court and that there was sufficient evidence to support Defendant's convictions.Specifically, the Supreme Court held (1) the trial court did not err in denying Defendant's motion to suppress his written statement to the police after finding that Defendant's statement was voluntary and reliable; (2) the trial court did not abuse its discretion in admitting into evidence the entirety of the cooperation agreement between the state and Defendant's accomplice regarding portions of the accomplice's obligation to testify truthfully; and (3) there was sufficient evidence to find Defendant guilty of attempt to commit robbery in the first degree, home invasion predicated on attempt to commit robbery in the first degree, burglary in the first degree, home invasion predicated on burglary in the first degree, and conspiracy to commit home invasion. View "State v. Flores" on Justia Law

The Supreme Court affirmed the judgment of the appellate court affirming the judgment the trial court convicting Defendant of murder, holding that a specific unanimity instruction was not required in this case.In affirming Defendant's conviction, the appellate court read this Court's precedents to mean that, although a jury must unanimously reject a self-defense claim before it may find a defendant guilty, there is no requirement that jurors agree on which specific factor of Connecticut's four-factor test for self-defense the state has disprove beyond a reasonable doubt. The appellate court affirmed. The Supreme Court affirmed, holding (1) a specific unanimity instruction was not required in this case; and (2) there was no reasonable possibility that Defendant's conviction resulted from the jurors' misunderstanding of the self-defense instruction, which the trial court reiterated several times and in various ways. View "State v. Mekoshvili" on Justia Law

The Supreme Court reversed Defendant's conviction of murder and criminal possession of a firearm in connection with the death of his wife, holding that the prosecutor improperly commented on Defendant's invocation of his right to remain silent following his arrest and advisement of rights pursuant to Miranda v. Arizona, 384 U.S. 436, 384 U.S. 436 (1966).On appeal, Defendant argued that the evidence was insufficient to establish his identity as the perpetrator of the crimes of conviction and that the prosecutor improperly commented on his post-Miranda silence. The Supreme Court reversed his convictions, holding (1) the evidence was sufficient to support the conviction; but (2) the prosecutor's remarks impermissibly used Defendant's post-Miranda silence against him, in violation of Doyle v. Ohio, 426 U.S. 610 (1976), rendering the trial "fundamentally unfair," and the error was not harmless. View "State v. Patrick M." on Justia Law

The Supreme Court affirmed Defendant's conviction of murder and carrying a dangerous weapon, holding that there was no deprivation of Defendant's due process right to a fair trial in this case.On appeal, Defendant argued that the prosecutor committed two instances of impropriety during the State's closing and rebuttal arguments, neither of which the defense objected to at trial. The Supreme Court upheld Defendant's convictions, holding (1) the first challenged argument did not exceed the bounds of permissible argument; and (2) as to the prosecutor's second challenged argument, even if the prosecutor's remarks were improper, there was no possibility that they deprived Defendant of a fair trial. View "State v. Hinds" on Justia Law

The Supreme Court reversed the judgment of the appellate court affirming Defendant's conviction of robbery in the first degree following the entry of his conditional plea of nolo contendere, holding that the prosecution of Defendant was time barred by the five-year statute of limitations set forth in Conn. Gen. Stat. 54-193(b).The robbery in this place took place on November 29, 2013. The next day, Defendant confessed to a detective as to his involvement in the robbery. On December 6, 2018, Defendant was transported to the superior court, where he was served with an arrest warrant. Defendant filed a motion to dismiss, arguing that the prosecution was barred under section 54-193(b). The trial court denied the motion to dismiss, finding that the State made at least some effort to execute the warrant on or before November 29, 2018. After Defendant entered his nolo contendere plea he appealed the denial of his motion to dismiss. The appellate court affirmed. The Supreme Court reversed, holding that the State did not meet its burden to demonstrate that the warrant for Defendant's arrest was executed without unreasonable delay. View "State v. Freeman" on Justia Law

The Supreme Court reversed in part the judgment of the appellate court upholding the trial court's denial of Defendant's motion to dismiss the charge of operating a motor vehicle while her license was under suspension, holding that that the State could not lawfully charge Defendant pursuant to Conn. Gen. Stat. 14-215(c).On appeal, Defendant argued that the forty-five-day license suspension period imposed on persons who refuse to submit to a chemical analysis of their breath, blood, or urine, as required by Conn. Gen. Stat. 14-227b(b), does not continue indefinitely until a time that the persons subject to the suspension install an ignition interlock device (IID) on their vehicle, but instead, terminates upon the expiration of the forty-five days. The appellate court disagreed and affirmed the denial of Defendant's motion to dismiss the charge of operating a motor vehicle with a suspended license. The Supreme Court reversed in part, holding (1) the suspension of a motor vehicle operator's license pursuant to section 14-227b(I)(1) does not continue until the operator has installed an IID but, rather, is limited to the forty-five days specified in the statute; and (2) because Defendant's license suspension period expired on December 2, she was not operating a motor vehicle while her operator's license was under suspension on December 4. View "State v. Schimanski" on Justia Law

The Supreme Court reversed the judgment of the appellate court concluding that the State had demonstrated good cause to amend its information during trial and that Defendant's substantive rights would not be prejudiced by the late amendment, holding that a new trial was required.After a jury trial, Defendant was convicted of two counts each of sexual assault in the first degree and sexual assault in the fourth degree and of three counts of risk of injury to a child. Defendant appealed, arguing that the trial court abused its discretion when it allowed the State to amend its information after the commencement of trial even though the State was aware that the time frame alleged in its information was inaccurate. The appellate court affirmed. The Supreme Court reversed, holding that the trial court abused its discretion in permitting the State's late amendment to its information. View "State v. Peluso" on Justia Law

The Supreme Court affirmed Defendant's conviction of murder, conspiracy to commit murder, and first degree assault, holding that the reversal of a codefendant's conviction does not necessitate the reversal of a defendant's conviction, despite the defendant's failure to preserve the issue at trial when the codefendant and defendant were jointly tried and the codefendant properly preserved the issue.Defendant's codefendant was granted a new trial premised on his objection to the State's untimely disclosure of an expert witness. Even though Defendant did not join in on his codefendant's objection to the untimely disclosed expert Defendant argued in this appeal that the Supreme Court should exercise its supervisory authority to reverse his conviction in the interest of justice. The Supreme Court affirmed, holding (1) fairness and justice do not require reversal of Defendant's conviction; and (2) this Court declines to overrule its decision in State v. Turner, 224 A.3d 129 (Conn. 2020), to review the merits of Defendant's unpreserved claim under State v. Edwards, 156 A.3d 506 (Conn. 2017). View "State v. Rogers" on Justia Law