Justia Connecticut Supreme Court Opinion Summaries

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 reversed the judgment of the trial court finding Plaintiffs responsible for failing to complete a project by the parties' agreed-upon deadline and awarding Defendant $335,000 in liquidated damages on its counterclaim, holding that the trial court's pretrial interpretation of various agreements between the parties was erroneous.At issue was which party was responsible for delays in constructing Dunkin Donuts Park in the City of Hartford. Plaintiffs, the project's developer and the design-builder, sued the City claiming breach of contract, and the City counterclaimed for breach of contract. The trial court concluded, as a matter of law, that Plaintiffs controlled the architect and were therefore liable for changes to and mistakes in the ballpark's design. Thereafter, the jury found Plaintiffs responsible for failing to complete the stadium by the agreed-upon deadline. The Supreme Court reversed, holding that the parties' contracts did not unambiguously grant Plaintiffs legal control of the architect and the stadium's design across all relevant time periods. View "Centerplan Construction Co. v. Hartford" 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

The Supreme Court reversed in part the judgment of the trial court awarding Plaintiff $200,309 in damages for Defendants' breach of a lease agreement, holding that the trial court improperly allocated the burden of proof as to mitigation in determining the damages award.At issue in this appeal was how the executive orders issued by Governor Ned Lamont during the earliest months of the COVID-19 pandemic affected the enforceability of a commercial lease agreement for premises that Defendants leased from Plaintiff. Both parties appealed from the judgment of the trial court awarding Plaintiff damages. The Supreme Court reversed in part, holding that the trial court (1) did not err in determining that the economic effects of the executive orders did not relieve Defendants of their obligations under the lease agreement; but (2) improperly relieved Defendants of their burden of proving that Plaintiff's efforts were commercially unreasonable under the circumstances, thus necessitating a new damages hearing. View "AGW Sono Partners, LLC v. Downtown Soho, LLC" on Justia Law

The Supreme Court reversed the judgment of the trial court accepting Defendant's plea of nolo contendere to robbery in the first degree and assault in the first degree and sentencing Defendant to an aggregate sentence of ten years' imprisonment, holding that a John Doe arrest warrant was invalid and could not commence prosecution for purposes of satisfying the statute of limitations.On appeal, Defendant argued that the John Doe arrest warrant that identified the suspect on the basis of a general physical description and several mixed partial DNA profiles to which the suspect may not have been a contributor and that did not state the probability that a random person would match any of the profiles did not satisfy the particularity requirement of the Fourth Amendment for purposes of commencing a prosecution within the applicable statute of limitations. The Supreme Court agreed, holding that, to satisfy the Fourth Amendment's particularity requirement, the affidavit accompanying a John Doe DNA arrest warrant application must contain information assuring the judicial authority issuing the warrant that the DNA profile identifies the person responsible for the crime on the basis of his or her unique DNA profile and should include information as to the statistical rarity of that DNA profile. View "State v. Police" on Justia Law

The Supreme Court exercised its supervisory authority to require that a trial court either canvass the defendant or, in certain circumstances, inquire of defense counsel directly to determine whether the defendant was properly advised regarding the waiver of his right to testify.Defendant was convicted of one count of sexual assault in the first degree following a jury trial at which he did not testify. On appeal, Defendant argued that defense counsel's representation that Defendant had waived his right to testify was insufficient to constitute a waiver of that right. The Supreme Court affirmed, holding (1) the constitution does not require that a defendant personally assert the waiver of his constitutional right to testify on the record; but (2) an on-the-record canvass of a defendant is the best practice to ensure that the defendant's waiver of his right to testify is made knowingly, intelligently and voluntarily. View "State v. Morel-Vargas" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of murder and carrying a pistol without a permit, holding that there was no error or abuse of discretion in the proceedings below.On appeal, Defendant argued that the trial court abused its discretion in excluding evidence of an assault of one of the state's witnesses and that the trial court erred by preventing him from impeaching another witness with evidence of previous criminal offenses. The Supreme Court affirmed, holding (1) the trial court's exclusion of evidence related to the assault did not violate Defendant's constitutional rights to present a defense and to confront the witnesses against him; and (2) the trial court did not violate Defendant's constitutional right to confrontation or the rules of evidence by preventing him from impeaching the witness with evidence of certain prior criminal convictions. View "State v. Torres" on Justia Law