Justia Connecticut Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the trial court denying Defendant's pretrial motion to dismiss for failure to prosecute him within the five-year limitation period set forth in Conn. Gen. Stat. 54-193a, holding that the trial court did not err.After a jury trial, Defendant was convicted of three counts of sexual assault in the first degree and one count of risk of injury to a child. On appeal, Defendant argued that the warrant for his arrest was not executed without unreasonable delay because the police did not execute the warrant until nearly sixteen years after its issuance. The Supreme Court affirmed, holding (1) Defendant did not satisfy his burden of establishing that he was available for arrest; and (2) therefore, the trial court properly denied Defendant's pretrial motion to dismiss the charges against him. View "State v. Juan F." on Justia Law

The Supreme Court reversed the judgment of the trial court convicting Defendant of sexual assault in the first degree, attempt to commit sexual assault in the first degree, and risk of injury to a child, holding that the trial court abused its discretion in admitting irrelevant, uncharged misconduct evidence.At issue on appeal was whether the trial court abused its discretion in admitting uncharged misconduct evidence of alleged prior incidents of sexual abuse of Defendant against the complainant. The Supreme Court answered in the positive, holding (1) in a general intent crime case where the theory of defense is that the alleged conduct did not occur, rather than a theory of defense in which the conduct occurred unintentionally, uncharged misconduct is irrelevant and inadmissible to prove intent; and (2) the uncharged misconduct evidence in this case was irrelevant to the issue of intent and was therefore inadmissible. View "State v. Juan J." on Justia Law

The Supreme Court affirmed the judgment of the appellate court affirming the judgment of the trial court convicting Defendant of murder, conspiracy to commit assault in the first degree, and other crimes, holding that Defendant was not entitled to relief on his claims of error.Specifically, the Supreme Court held that the appellate court correctly concluded that the trial court had not abused its discretion by admitting an audio recording allegedly containing Defendant's confession into evidence and by directing the jury to disregard portions of defense counsel's closing argument. The Supreme Court affirmed, holding (1) the trial court did not abuse its discretion in admitting the audio recording into evidence; and (2) any error by the trial court in precluding certain arguments made by defense counsel was harmless. View "State v. Rivera" on Justia Law

The Supreme Court affirmed the judgment of the appellate court affirming the trial court's judgment convicting Defendant of one count of murder, holding that Defendant was not entitled to relief on any of his allegations on appeal.Specifically, the Supreme Court held that the appellate court correctly concluded that the trial court (1) did not violate Defendant's Sixth Amendment right to present a defense by excluding from evidence a statement purportedly made by an unknown female bystander and an autopsy toxicology report; (2) did not violate Defendant's right to due process by declining to give a jury instruction on self-defense; and (3) did not abuse its discretion by declining to sanction the state for its late disclosure of the murder weapon and related expert reports by excluding this evidence or dismissing the murder charge. The Court further cautioned the State regarding the late disclosure of evidence. View "State v. Hargett" on Justia Law

Convicted of murder in connection with a shooting death during a drug transaction, Ortiz challenged the prosecutor’s response, in rebuttal, to defense statements (made contrary to a pre-trial agreement) that, if the jury felt that he made a tactical mistake by not cross-examining the witness, it should not hold that against Ortiz; the prosecutor stated that there was no question about who the witness was with and what she saw, and that defense counsel ‘‘didn’t even [cross-examine] her.’’The Connecticut Supreme Court affirmed. Any impropriety did not deprive Ortiz of a fair trial, as the prosecutor’s argument was brief, defense counsel did not object or ask for curative measures, and the defense invited the statement to some extent. Although the alleged impropriety related to witness credibility, an important issue, there was no reasonable probability that the verdict would have been different without the alleged impropriety. The trial court did not abuse its discretion in precluding defense counsel from impeaching other witnesses with evidence of certain prior felony convictions and in requiring two prior convictions to be referred to only as unnamed felonies punishable by more than one year of imprisonment. The trial court properly declined Ortiz’s request to include the word ‘‘conclusively’’ in its jury instruction on the use of evidence of the defendant’s uncharged misconduct. View "State v. Ortiz" on Justia Law

The Supreme Court affirmed Defendant's conviction of felony murder, attempt to commit robbery in the first degree, and other offenses, holding that the trial court did not err in denying Defendant's motion for a new trial.After Defendant was found guilty but before sentencing the Supreme Court decided State v. Purcell, 203 A.3d 542 (Conn. 2019). Defendant subsequently filed a motion for a new trial based on Purcell, arguing that the State's evidence at trial had included a video-recorded statement in which Defendant had made an equivocal request for counsel. The trial court agreed that Defendant's video-recorded statements was improperly admitted into evidence, but, with the exception of Defendant's conviction of carrying a pistol without a permit, the error was harmless. The Supreme Court affirmed, holding that the improper admission of Defendant's video-recorded statement was harmless beyond a reasonable doubt and that the trial court properly denied Defendant's motion for a new trial with respect to all but one of his convictions. View "State v. Alexander" on Justia Law

The Supreme Court affirmed Defendant's conviction of home invasion, attempt to commit assault, reckless endangerment in the first degree, and two counts of risk of injury to a child, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Court held (1) the evidence was sufficient to support the convictions; (2) the jury did not return a legally inconsistent verdict in connection with the crimes of attempt to commit assault in the first degree and reckless endangerment; and (3) home invasion and attempt to commit assault in the first degree are not the same offense for double jeopardy purposes. View "State v. Abraham" on Justia Law

The Supreme Court affirmed in part the judgment of the trial court dismissing in part and denying in part Defendant's two motions to correct an illegal sentence, one filed in each of his two criminal cases, holding that the trial court erred in part.Defendant was convicted in two separate cases for crimes he committed when he was fifteen years old. The trial court dismissed in part and denied in part Defendant's two motions to correct an illegal sentence, concluding that it lacked jurisdiction over Defendant's claims to correct, and that Defendant was not entitled to relief on his claim that his parole eligibility date, as calculated by the Board of Pardons and Parole, violated the terms of his plea agreement. The Supreme Court vacated in part, holding (1) the trial court should have denied, rather than dismissed, Defendant's claims that he was entitled to resentencing pursuant to Miller v. Alabama, 567 U.S. 460 (2012); and (2) the form of the judgment was improper insofar as the trial court denied Defendant's claim that his new parole eligibility date violated the terms of his plea agreement. View "State v. Myers" on Justia Law

The Supreme Court affirmed the opinion of the appellate court affirming the judgment of the habeas court dismissing Petitioner's second petition for a writ of habeas corpus following its determination that Petitioner had failed to establish good cause for the delayed filing of that second petition, holding that there was no error in the proceedings below.Petitioner, an inmate convicted of conspiracy to commit robbery in the first degree, filed the underlying petition for a writ of habeas corpus raising seven claims not raised in his earlier petition. The habeas court ultimately dismissed the petition, concluding that Petitioner failed to establish good cause for filing the petition nearly three years past the statutory deadline. The appellate court affirmed. The Supreme Court affirmed, holding that the habeas court did not abuse its discretion in determining that Petitioner failed to demonstrate good cause for the delay in filing his second habeas petition. View "Kelsey v. Commissioner of Correction" on Justia Law

The Supreme Court affirmed the judgment of the habeas court granting Petitioner's petition for writ of habeas corpus after determining that Petitioner had suffered prejudice as a result of the ineffective assistance of his trial counsel, holding that there was no error.In granting habeas relief, the habeas court determined that Petitioner's trial counsel failed to provide Petitioner with professional advise and assistance during pretrial plea negotiations and that Petitioner would have accepted the trial court's pretrial plea offer but for the ineffective assistance of Petitioner's trial counsel. The Supreme Court affirmed, holding that the habeas court did not err in concluding that Petitioner had fulfilled his burden of establishing prejudice. View "Barlow v. Commissioner of Correction" on Justia Law