Justia Connecticut Supreme Court Opinion Summaries

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 the decision of the appellate court affirming the judgment of the trial court concluding that Defendant's allegedly defamatory statements about Plaintiff made during a hearing before the Greenwich Planning and Zoning Commission were entitled to statutory immunity, holding that the appellate court erred.Plaintiff brought this defamation action seeking to recover damages for injuries he claims to have sustained as a result of Defendant's alleged defamatory statements. The trial court granted Defendant's motion to dismiss, concluding that it did not have jurisdiction over Plaintiff's claims because the statements Defendant made about Plaintiff at the commission's hearing were entitled to absolute immunity because the hearing constituted a quasi-judicial proceeding. The appellate court affirmed. The Supreme Court reversed, holding (1) a hearing on a special permit application before a town's planning and zoning commission is not quasi-judicial in nature; and (2) therefore, the appellate court erroneously determined that Defendant's statements were entitled to absolute immunity. View "Priore v. Haig" 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 the judgment of the trial court dismissing the appeal brought by the Board of Education of the City of New Haven after a human rights referee concluded that the Board had discriminated against a student on the basis of his disabilities and awarding damages of $25,000, holding that the Board was not entitled to relief on its claims of error.Specifically, the Supreme Court held (1) the trial court did not err in determining that the Commission on Human Rights and Opportunities had subject matter jurisdiction to adjudicate the student's claim that the Board had violated the Americans with Disabilities Act, 42 U.S.C. 12101 et seq.; (2) the trial court properly concluded that the Commission had subject matter jurisdiction over the student's claims when his father failed to exhaust his administrative remedies pursuant to the Individuals with Disabilities Education Act, 20 U.S.C. 1400 et seq.; and (3) the Board's third claim was not reviewable on appeal. View "Board of Education v. Commission on Human Rights & Opportunities" 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 reversing in part the judgment of the trial court in favor of Plaintiff in this personal injury action against a police officer and his employer, holding that Defendants were not entitled to discretionary act immunity under the circumstances of this case.Plaintiff was riding his motorcycle when Zachary Kashmanian, a police officer, began pursuing him. Kashmanian struck the back tire of Plaintiff's motorcycle, causing Plaintiff to crash and sustain serious injuries. Plaintiff asserted a common-law negligence claim against Kashmanian and the City and a common-law recklessness claim against Kashmanian. The court granted Kashmanian's motion for a directed verdict as to count two, and the jury returned a verdict for Plaintiff on the negligence count. The trial court then set aside the jury's verdict in favor of Plaintiff on the negligence claim, concluding that governmental immunity was applicable to Kashmanian's conduct. The court of appeals remanded for a directed verdict in favor of Kashmanian on the recklessness count. The Supreme Court reversed the portion of the appellate court's judgment insofar as that court upheld the trial court's motion to set aside the jury's verdict on the negligence complaint, holding that Kashmanian's operation of a "soft car" was a ministerial act for purposes of Defendants' governmental immunity. View "Daley v. Kashmanian" 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 reversed the judgment of the appellate court dismissing Petitioner's appeal from the judgment of the habeas court denying his petition for a writ of habeas corpus, holding that Petitioner failed to prove his claim that his counsel labored under an actual conflict of interest.At issue was whether the habeas court abused its discretion in denying Petitioner's petition for certification to appeal with respect to his claim that his defense counsel rendered ineffective assistance during his second criminal trial by simultaneously working as defense counsel and as an active duty police officer in a different city, which Petitioner claimed was a conflict of interest. The Supreme Court affirmed, holding that defense counsel's actions did not rise to the level of an actual conflict of interest for purposes of the Sixth Amendment. View "Diaz v. Commissioner of Correction" on Justia Law