Justia Connecticut Supreme Court Opinion Summaries

The Supreme Court affirmed the decision of the appellate court reversing the judgment of the habeas court granting Petitioner's petition for a writ of habeas corpus, holding that Petitioner failed to satisfy his burden under Strickland v. Washington, 466 U.S. 668 (1984), to establish his claims of ineffective assistance of counsel.Petitioner was convicted of manslaughter in the first degree with a firearm and sentenced to forty years' imprisonment with respect to this charge. In his habeas petition, Petitioner argued, among other things, that his trial counsel provided ineffective assistance by failing to call six additional eyewitnesses to testify at the underlying criminal trial. The habeas court granted relief. The appellate court reversed. The Supreme Court affirmed, holding that Petitioner failed to show prejudice on either of his ineffective assistance of counsel claims. View "Jordan v. Commissioner of Correction" on Justia Law

In this appeal concerning the conditions under which a member of a manager-managed limited liability company (LLC) is permitted to inspect the LLC's books and records the Supreme Court affirmed the judgment of the trial court concluding that Defendant's refusal to disclose certain information to Plaintiffs violated both Conn. Gen. Stat. 34-255i and Defendant's operating agreement, holding that there was no error.At issue was whether a member seeking information for the purpose of ascertaining whether mismanagement occurred must produce credible proof that mismanagement may have occurred as a condition for exercising that member's statutory inspection right. The Supreme Court affirmed the trial court's ruling in favor of the substitute plaintiffs in this case, holding that the court did not err in (1) concluding that there is no credible proof of mismanagement requirement in section 34-255i; and (2) failing to apply other statutory requirements. View "Benjamin v. Island Management, LLC" on Justia Law

The Supreme Court reversed the judgment of the appellate court affirming the trial court's dismissal of Defendant's motion to correct a sentence imposed in an illegal manner, holding that the appellate court erred in concluding that the trial court lacked subject matter jurisdiction to correct the sentence.Defendant pleaded guilty to manslaughter in the first degree and assault in the first degree. The trial court sentenced him to a total term of twenty-five years of incarceration. Defendant later filed a motion to correct, arguing that the trial court imposed the sentence in an illegal manner. The trial court concluded that it lacked subject matter jurisdiction over his motion to correct on the ground that the motion constituted a collateral attack on Defendant's conviction, not his sentence. The appellate court affirmed, holding that Defendant had failed to raise a colorable claim within the scope of Practice Book 43-22. The Supreme Court reversed, holding (1) Defendant showed a possibility that a factual basis necessary to establish jurisdiction existed; and (2) therefore, the appellate court improperly affirmed the trial court's dismissal of Defendant's motion to correct. View "State v. Ward" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of manslaughter in the first degree, holding that the trial court did not abuse its discretion in admitting certain evidence.During trial and in an effort to support his self-defense theory, Defendant sought to admit evidence that the victim had searched an Internet shopping site for weapons in the days leading up to the incident in which Defendant fatally stabbed the victim. The trial court concluded that the evidence was not admissible, relevant or material and denied Defendant's motion in limine to admit the evidence. Defendant challenged this ruling on appeal, arguing that the evidence was both relevant and admissible as uncharged misconduct evidence. The Supreme Court disagreed, holding that the trial court did not abuse its discretion in declining to admit into evidence the victim's Internet searches for weapons. View "State v. Streit" on Justia Law

The Supreme Court affirmed the judgment of the appellate court affirming the trial court's judgment resentencing Defendant for crimes he committed when he was seventeen years old, holding that Conn. Gen. Stat. 54-91g did not apply to Defendant.This case arose from the carjacking, kidnapping, and murder of the victim by Defendant and another individual. Defendant was tried as an adult under the then applicable law and sentenced to life imprisonment without the possibility parole. Later changes in juvenile sentencing law prompted the resentencing proceedings at issue on appeal. Defendant filed a motion to correct an illegal sentence, which the trial court granted, sentencing Defendant to a total effective sentence of eighty years' imprisonment. Defendant appealed, arguing that the trial court had failed to adhere to the requirements of section 54-91g. The Supreme Court affirmed, holding that section 54-91g did not apply to Defendant. View "State v. Coltherst" on Justia Law

The Supreme Court affirmed the judgment of the trial court dismissing Appellants' appeal from the decision of the Planning and Zoning Commission of the City of Shelton approving an application for a planned development district submitted by Shelter Ridge Associates, LLC, holding that the trial court did not err or abuse its discretion.Specifically, the Supreme Court held (1) contrary to Appellants' argument on appeal, the zoning authority conferred by Conn. Gen. Stat. 8-2 supports the creation of planned development districts; (2) the planned development district proposed by Shelter Ridge did not violate the uniformity requirement contained in section 8-2; and (3) the Commission’s decision did not result in an unlawful subdivision. View "Tillman v. Planning & Zoning Commission of the City of Shelton" on Justia Law

The Supreme Court affirmed the judgment of the appellate court affirming the trial court's judgments following Defendant's conditional pleas of nolo contendere to charges of sale of a controlled substance and violation of probation, holding that Defendant could not meet the requirements to establish classical aggrievement.On appeal, Defendant, who was Caucasian, argued that his conviction violated his right to due process because the statute under which he was convicted violates the Equal Protection Clause of the United States Constitution because it was enacted to discriminate against African Americans and Mexican Americans. The appellate court affirmed, ruling that Defendant could not bring his constitutional challenge in his individual capacity based on the alleged violation of others' equal protection rights. The Supreme Court affirmed, holding that Defendant failed to meet the requirements to establish classical aggrievement. View "State v. Bradley" on Justia Law

The Supreme Court affirmed the decision of the trial court granting Defendant's motion to dismiss the information against him, holding that the trial court did not err in concluding that the statute of limitations was not tolled by Conn. Gen. Stat. 54-193(c).Defendant was charged with possession of child pornography in the first degree. Pursuant to a warrant, Defendant was arrested nearly five years after the warrant was issued and more than three years after the applicable statute of limitations had expired. The trial court granted Defendant's motion to dismiss, concluding (1) the tolling provision of section 54-193(c) was inapplicable once the warrant was issued within the limitation period, and (2) the almost five-year delay in executing the warrant was unreasonable under State v. Crawford, 521 A.2d 1034 (Conn. 1987). The Supreme Court affirmed, holding that although section 54-193 (c) tolls the limitation period within which a prosecution may be commenced, Crawford and its progeny establish that, once an arrest warrant has been issued, the State must serve the warrant without undue delay. View "State v. A.B." 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 Plaintiffs, the town of South Windsor and its zoning enforcement officer and remanding the case for a new trial on count two of the complaint, holding that the appellate court improperly remanded the case.The trial court assessed a fine and imposed injunctive relief for certain zoning violations pursuant to Conn. Gen. Stat. 8-12. The appellate court remanded the case for a new trial, concluding that the trial court had improperly assessed a fine on Defendant for zoning violations for a period of time that she was under lawful orders not to disturb her property because of an ongoing fire investigation. The Supreme Court reversed, holding that no dispute remained as to Defendant's liability for the zoning violations alleged in count two of Plaintiffs' complaint. View "Town of South Windsor v. Lanata" on Justia Law

The Supreme Court affirmed the judgment of the appellate court affirming the trial court's dismissal of the statutory theft claim Plaintiff brought against Defendant for lack of subject matter jurisdiction on the ground of absolute immunity, holding that there was no error.Defendant, an attorney, represented Benchmark Municipal Tax Services, Ltd., in the foreclosure proceeding underlying this appeal. The appellate court determined that Defendant was entitled to absolute immunity from Plaintiff's claim of statutory theft by concluding that public policy considerations were served by granting Defendant this immunity and that the entirety of Defendant's alleged misconduct occurred within the scope of the foreclosure proceeding. The Supreme Court affirmed, holding that Plaintiff's arguments on appeal failed. View "Scholz v. Epstein" on Justia Law