Justia Connecticut Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the appellate court affirming the trial court's judgment of conviction of murder, holding that the appellate court correctly concluded that any error relating to the admission of testimony from a witness called during the state's case on rebuttal was harmless.On appeal, Defendant argued that the testimony of Mark Manganello, the witness at issue, fatally undermined her theory of self defense and that the testimony likely had a substantial effect on the jury's verdict. The Supreme Court disagreed, holding that the appellate court properly concluded that any evidentiary error committed by the trial court with respect to the admission of Manganello's testimony was necessarily harmless. View "State v. Carey" on Justia Law

The Supreme Court reversed the judgment of the appellate court affirming Defendant's conviction of six counts of sexual assault and four counts of risk of injury to a child from the sexual abuse of his girlfriend's daughter, J, holding that the trial court erred in excluding screenshot photographs of text messages purportedly sent by J to Defendant's niece.Specifically, the Supreme Court held (1) the appellate court correctly upheld the admission into evidence of a video recording of a forensic interview of J by a nonmedical professional under the medical diagnosis and treatment exception to the hearsay rule; but (2) the appellate court incorrectly concluded that the trial court had properly excluded J's text messages on the ground that they had not been sufficiently authenticated, and the improper exclusion of the text messages requires reversal of the judgment and a new trial. View "State v. Manuel T." on Justia Law

The Supreme Court reversed the judgment of conviction rendered by the trial court following Defendant's conditional plea of nolo contendere to the charge of possession of a controlled substance with intent to sell, holding that the trial court erred in denying Defendant's motion to suppress.Defendant sought to suppress evidence seized after his warrantless detention in the parking lot of a multiunit apartment building. The trial court denied the suppression motion. The Supreme Court reversed, holding that Defendant was not an "occupant" within the "immediate vicinity" of the premises subject to a search warrant under the exception to the Fourth Amendment's warrant requirement set forth in Michigan v. Summers, 452 U.S. 692 (1981), and Bailey v. United States, 568 U.S. 186 (2013). View "State v. Rolon" on Justia Law

The Supreme Court reversed the judgment of conviction rendered by the trial court following Defendant's conditional plea of nolo contendere to the charge of possession of a controlled substance with intent to sell, holding that the trial court erred in denying Defendant's motion to suppress.On appeal, Defendant argued that she was illegally detained, along with her codefendant, in a car in the parking lot of a multiunit apartment building because the police lacked either a warrant or a reasonable, articulable suspicion of criminal activity. The Supreme Court reversed, holding that Defendant's detention was not permissible under the exception to the Fourth Amendment's warrant requirement articulated in Michigan v. Summers, 452 U.S. 692, and Bailey v. United States, 568 U.S. 186 (2013) because Defendant was not within the "immediate vicinity" of the apartment to be searched. View "State v. Espino" on Justia Law

The Supreme Court affirmed the decision of the Appellate Court affirming the judgments of the trial court convicting Defendant of, among other charges, aggravated sexual assault in the first degree and risk of injury to a child, holding that the trial court properly found that Defendant's waiver of his right to a jury trial was constitutionally valid.Following a seven day trial to the court, Defendant was found guilty of multiple offenses. On appeal, Defendant challenged the finding of the trial court that his jury trial waiver was knowing, intelligent, and voluntary. The Appellate Court affirmed. Defendant appealed, arguing that the trial court should have recognized that he was unready and incapable of waiving a jury trial. The Supreme Court affirmed, holding that the Appellate Court's opinion fully addressed Defendant's arguments, and there was no need to repeat that discussion. View "State v. Kerlyn T." on Justia Law

In this public nuisance action, the Supreme Court reversed the judgment of the Appellate Court concluding that the trial court abused its discretion when it denied Plaintiff's motion to set aside the verdict due to an alleged fatal inconsistency between two special interrogatories, holding that the jury's answers to the two special interrogatories were not inconsistent.Plaintiff alleged that the Town of Redding should have guarded a specific retaining wall located outside of a local pub by a fancy and that the absence of a fence constituted an absolute public nuisance and caused him to sustain personal injuries. The trial court rendered judgment in favor of Defendant. The Appellate Court reversed, concluding that the jury's response to the first special interrogatory - that the unfenced retaining wall was inherently dangerous - was fatally inconsistent with the jury's response to the third special interrogatory - that the Town's use of the land was reasonable. The Supreme Court reversed, holding that the jury's answers to the first and third special interrogatories could be harmonized in light of established nuisance jurisprudence. View "Fisk v. Redding" on Justia Law

The Supreme Court affirmed Defendant's conviction of murder, two counts of attempted murder and related crimes, holding that the trial court did not abuse its discretion in admitting into evidence four photographs that depicted the bloody interior of a vehicle used to transport two victims shot by Defendant to the hospital.At Defendant's second jury trial on murder, attempted murder, and first degree assault charges, the State admitted into evidence four photographs of the bloody interior of the car that one victim used to drive herself and other victim to the hospital. On appeal, Defendant argued that the four photographs were unduly prejudicial because of their inflammatory nature and that the evidentiary error was harmful. The Supreme Court affirmed, holding that the trial court's determination that the photographs were more probative than prejudicial was not an abuse of discretion. View "State v. Best" on Justia Law

In this personal injury action, the Supreme Court reversed the judgment of the trial court granting summary judgment in favor of Defendants - the City of New Haven and one of its police officers, Nikki Curry - holding that the trial court incorrectly determined that Defendants were entitled to governmental immunity for discretionary acts pursuant to Conn. Gen. Stat. 52-557n(a)(2)(B).On appeal, Plaintiff argued that the trial court erred in determining that Curry's decision to drive her vehicle into oncoming traffic was a discretionary act, rather than a ministerial act, because Curry's actions violated policies imposing ministerial duties regarding the operation of police vehicles, pursuits, and roadblocks. The Supreme Court agreed and reversed, holding that the trial court improperly granted Defendants' motion for summary judgment on discretionary immunity grounds. View "Cole v. City of New Haven" on Justia Law

The Supreme Court reversed the judgment of the habeas court denying Petitioner's petition for certification to appeal from the dismissal of his petition for a writ of habeas corpus, holding that the habeas court should have declined to issue the writ pursuant to Practice Book 23-24 rather than dismissing the case pursuant to Practice Book 23-29.Acting sua sponte and without providing Petitioner with notice or a hearing, the habeas court dismissed Petitioner's habeas petition pursuant to section 23-29 for lack of jurisdiction on the grounds that Petitioner was not in custody for the conviction being challenged. The Supreme Court reversed, holding (1) the habeas court correctly determined that it lacked subject matter jurisdiction because Petitioner was not in custody for the challenged conviction; but (2) the dismissal of the petition pursuant to Practice Book 23-29 was error. View "Cookish v. Commissioner of Correction" on Justia Law

In this summary process action for nonpayment of rent under the terms of a commercial lease the Supreme Court affirmed the judgment of the Appellate Court affirming the trial court's judgment of possession rendered in favor of Plaintiffs, holding that the trial court properly denied Defendants equitable relief from forfeiture of their tenancy.After the Appellate Court affirmed the trial court's judgment of possession rendered in favor of Plaintiffs, Defendants appealed, arguing that the trial court erred in denying their special defense of equitable nonforfeiture. The Supreme Court affirmed, holding that, under the facts of this case, the trial court did not abuse its discretion in refusing to grant Defendants equitable relief from forfeiture. View "Boccanfuso v. Daghoghi" on Justia Law