Justia Connecticut Supreme Court Opinion Summaries

The Supreme Court affirmed Defendant's conviction of murder in violation of Conn. Gen. Stat. 53a-54a, holding that the trial court did not abuse its discretion by admitting evidence of uncharged misconduct, namely, two prior shootings involving the alleged murder weapon, to prove identity and means.On appeal, Defendant argued that the evidence was not relevant or material to identity and that the probative value of the evidence was outweighed by its prejudicial effect. The Supreme Court disagreed and affirmed, holding that, given the manner in which the testimony was limited and the numerous cautionary instructions given to the jurors, the trial court did not abuse its discretion in admitting the uncharged misconduct evidence. View "State v. Patterson" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of felony murder, robbery in the first degree, and other crimes, holding that any error in the trial court's failure to suppress evidence obtained from a search warrant was harmless.On appeal, Defendant challenged the trial court's denial of his motion to suppress evidence obtained from a search of his cell phone, arguing that the application for the warrant authorizing the search lacked a particular description of the items to be seized and that the affidavit supporting the application failed to establish probable cause. The Supreme Court affirmed, holding that the State met its burden of showing that any error in the denial of Defendant's motion to suppress was harmless beyond a reasonable doubt. View "State v. Bowden" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the trial convicting Defendant of various crimes arising from five criminal cases, which included first degree robbery, second degree arson, and attempt to commit murder, holding that the trial court erred in denying Defendant's motion to suppress.At issue on appeal was the trial court's denial of Defendant's motion to suppress evidence discovered during a search of his cell phone and evidence obtained from his cell phone service provider. Specifically in question was whether the warrants authorizing those searches were supported by probable cause and whether they particularly described the place to be searched and the things to be seized. The Supreme Court reversed in part, holding (1) the trial court erred in denying Defendant's motion to suppress the information obtained from the execution of both warrants; and (2) this error was harmless with respect to some, but not all, of the crimes alleged in the indictment. View "State v. Smith" on Justia Law

The Supreme Court affirmed Defendant's convictions of murder, assault in the first degree by means of the discharge of a firearm, and attempt to commit assault in the first degree by means of the discharge of a firearm, holding that there was no violation of Defendant's Fourth Amendment rights in this case.On appeal, Defendant argued that the trial court erred in denying his motion to suppress evidence seized from his father on the grounds that the police officers' warrantless entry into the residence home under the emergency exception to the Fourth Amendment warrant requirement was justified. Alternatively, the court deterred that, even if the initial entry was unlawful, Defendant's shooting of the victim sufficiently attenuated that unlawful act from the subsequent lawful search and seizure of the evidence at issue. The Supreme Court affirmed, holding that (1) under the totality of the circumstances, it was objectively reasonable for the officers to conclude that there was an emergency justifying their initial entry into the residence; and (2) in light of this conclusion, the subsequent entries were similarly justified. View "State v. Samuolis" on Justia Law

The Supreme Court reversed in part the judgment of the trial court rendered primarily in favor of the Town of Colebrook in this municipal property tax appeal, holding that equipment associated with wind turbines should have been classified as personal, rather than real, property.In its appeal, Plaintiff argued that the trial court improperly upheld the Town's classification of its two wind turbines and their associated equipment as real property pursuant to Conn. Gen. Stat. 12-64(a). The Supreme Court agreed in part, holding (1) the wind turbines were properly classified as real property; but (2) the associated equipment must be treated as personal property pursuant to Conn. Gen. Stat. 12-41(c). View "Wind Colebrook South, LLC v. Colebrook" on Justia Law

The Supreme Court affirmed the judgment of the trial court on remand determining that Defendant had failed to establish that defense counsel, Kirstin Coffin, had a conflict of interest, holding that there was no error.Defendant was convicted of murder and sentenced to a fifty-year term of incarceration. On appeal, the Supreme Court held that the trial court had a duty to inquire into Coffin's alleged conflict of interest and remanded for a determination as to whether Defendant's claim had merit. After a hearing on remand, the trial court concluded that Defendant had failed to establish that Coffin was burdened by an actual conflict of interest as a result of her prior representation of Defendant. The Supreme Court affirmed, holding (1) there was no error in the determination that Coffin was not burdened by an actual conflict of interest that adversely affected her performance; and (2) Defendant's remaining claim was without merit. View "State v. Davis" on Justia Law

The Supreme Court dismissed as moot Defendant's appeal from the judgment of conviction, rendered after a jury trial, of murder and criminal possession of a firearm by a convicted felon, holding that Defendant was not entitled to relief.On appeal, Defendant argued that the trial court violated his Sixth Amendment right to present a defense by precluding an expert witness proffered by defense counsel from testifying as to Defendant's location during certain relevant time periods on the basis of cell phone carrier data. The Supreme Court dismissed Defendant's appeal, holding (1) Defendant failed to challenge all of the independent bases of the trial court's evidentiary ruling; and (2) therefore, this Court could not provide Defendant practical relief. View "State v. Council" on Justia Law

The Supreme Court held that a claim brought pursuant to Conn. Gen. Stat. 52-557n(b)(8) is a "cause of action created by statute based on negligence" such that apportionment is allowed under Conn. Gen. Stat. 52-572h(o).At issue was whether the apportionment statute, section 52-572h, permits municipal defendants whose liability is based on section 52-557n(b)(8) to file an apportionment complaint sounding in negligence. The trial court dismissed Defendants' apportionment complaint, but the appellate court reversed, concluding that Plaintiff's claims under section 52-557n(b)(8) fell within the first exception, which it held to incorporate a negligence standard. The Supreme Court affirmed, holding that because section 52-557n(b)(8) expressly abrogates the common law doctrine of municipal immunity and because the first exception under the statute allows for a cause of action based on negligence, claims brought pursuant to that exception qualify for apportionment. View "Costanzo v. Plainfield" on Justia Law

The Supreme Court reversed the appellate court's judgment reversing in part the decision of the Town Plan and Zoning Commission of the Town of Fairfield extending its approvals of a special permit and a coastal site plan review granted to Fairfield Commons, LLC, holding that a local zoning authority may not, by regulation, condition the continuing validity of a special permit on completing development in connection with the permitted use within a period of time that is shorter than the statutory period.The appellate court in this case affirmed the trial court's judgment concluding that the Commission improperly granted Fairfield Commons' request for an extension of its special permit deadline to complete development but reversed the court's conclusion that the special permit could not be subject to a temporal limitation as a matter of law. The Supreme Court reversed, holding (1) a special permit regulation may not prescribe a shorter time limitation for completing development than the statutory period set forth for completion of development in connection with an accompanying site plan under Conn. Gen. Stat. 8-3(i) and (m); and (2) the appellate court incorrectly concluded that the special permit at issue expired in April 2011. View "International Investors v. Town Plan & Zoning Commission" on Justia Law

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