Justia Connecticut Supreme Court Opinion Summaries

The defendant was convicted of murder and carrying a pistol or revolver without a permit. The key evidence against him included two recorded police interviews with Daequan Carr, the state's primary witness, who identified the defendant as the shooter. Carr was uncooperative at trial, leading the prosecution to introduce his prior statements under the Whelan rule, which allows prior inconsistent statements to be used substantively if certain conditions are met.The trial court admitted Carr's interviews, finding his trial testimony inconsistent with his prior statements. Carr's father, Dennis Cobia, also made statements during one interview, which the court allowed to the extent Carr adopted them. The jury found the defendant guilty, and he was sentenced to fifty-five years in prison.The defendant appealed, arguing that Carr's trial testimony was not inconsistent with his prior statements and that the trial court erred in admitting Cobia's statements. He also contended that the court improperly admitted a Facebook photo and Snapchat video showing him with items similar to those used in the crime.The Connecticut Supreme Court found that the trial court abused its discretion in admitting Carr's interviews. Carr's ambiguous statements about his recollection did not clearly establish inconsistency, and the prosecution did not sufficiently probe his memory or attempt to refresh it. The court also failed to adequately determine whether Carr refused to testify. The error was not harmless, as Carr's identification of the defendant was crucial, and no other evidence directly linked the defendant to the crime.The court clarified that adopted statements could be admitted under Whelan if unequivocally adopted by the witness. However, the trial court improperly delegated to the jury the task of determining which of Cobia's statements were adopted by Carr. The court upheld the admission of the Facebook photo and Snapchat video, finding their probative value outweighed any prejudicial effect.The judgment was reversed, and the case was remanded for a new trial. View "State v. Hamilton" on Justia Law

The defendant was convicted of murder after fatally stabbing his girlfriend in their shared apartment. The incident occurred while the victim’s son was home, though he did not witness the attack. After the killing, the defendant fled in the victim’s car and communicated with family members via Facebook, making statements about the altercation and his intent to leave the country. He was later apprehended in New York, where he made statements to police both spontaneously and during a subsequent interview, in which he confessed to the killing. During the police interview, photographs were taken of the defendant to document any injuries.In the Superior Court for the judicial district of Waterbury, the defendant moved to suppress his statement to the Waterbury police, arguing it was obtained in violation of his right to counsel under Miranda and Edwards. The trial court agreed in part, suppressing the statement from the prosecution’s case-in-chief but allowing its use for impeachment if the defendant testified, relying on State v. Reid. The court also admitted photographs taken of the defendant, finding they were obtained through standard police procedure and not as a result of the Miranda violation. Additionally, the court permitted the late disclosure of a witness, the victim’s sister-in-law, after finding no prejudice to the defense.The Connecticut Supreme Court affirmed the conviction. It held that the state constitution does not prohibit the use of a voluntary statement obtained in violation of Miranda for impeachment purposes, declining to overrule State v. Reid. The court also held that the photographs were admissible because they had an independent source in routine police procedure. Finally, the court found no abuse of discretion or violation of the defendant’s right to a fair trial in allowing the late-disclosed witness to testify, as the defendant suffered no demonstrable prejudice. View "State v. Haynes" on Justia Law

The case involved a fatal stabbing that occurred during a confrontation inside the victim’s apartment. The defendant and the victim were both acquainted with a woman named Menendez, who had relationships with both men. In the period leading up to the incident, the defendant became increasingly controlling and jealous regarding Menendez’s interactions with the victim. On the day of the stabbing, Menendez was staying with the victim, and after a series of tense interactions and text messages, the defendant arrived at the victim’s apartment. Shortly after the defendant’s arrival, a violent altercation ensued, resulting in the victim being stabbed in the chest and later dying from his injuries. The defendant admitted to stabbing the victim but claimed he acted in self-defense, asserting that the victim attacked him with a knife first.The case was tried before the Superior Court in the judicial district of Hartford. At trial, the state presented testimony from Menendez, a medical examiner, a detective, and an inmate who had shared a cell with the defendant. The state’s evidence included testimony that contradicted the defendant’s account, suggesting that the defendant brought the knife to the apartment and was the only person armed during the struggle. The jury found the defendant guilty of murder, rejecting his self-defense claim. The defendant was sentenced to thirty-five years of incarceration and appealed his conviction, arguing that the evidence was insufficient to disprove his claim of self-defense beyond a reasonable doubt.The Connecticut Supreme Court reviewed the case. The court held that the state presented sufficient evidence for the jury to find, beyond a reasonable doubt, that the defendant either did not actually believe he was in imminent danger of deadly physical force or, if he did, that such a belief was not objectively reasonable. The court affirmed the conviction, concluding that the state met its burden of disproving the defendant’s justification defense. View "State v. Ramsey" on Justia Law

The defendant was convicted of felony murder and attempted robbery in the first degree, among other charges, following an incident where another individual, Christian, shot and killed the victim, Rodney, during a scuffle that ensued after the defendant attempted to rob Rivera. The defendant appealed, arguing that the state needed to prove that Christian was an accessory to the attempted robbery to secure a felony murder conviction.The trial court had instructed the jury on the felony murder statute, which does not require the state to prove that a participant in the crime was an accessory. The defendant was found guilty of felony murder, attempted robbery, and firearm offenses, but not guilty of murder as an accessory. The trial court vacated the manslaughter conviction on double jeopardy grounds and sentenced the defendant to forty years in prison.The Connecticut Supreme Court reviewed the case and held that the felony murder statute does not require the state to establish that a participant who caused the death was an accessory to the predicate felony. The court found sufficient evidence to support the conviction, noting that Christian's actions were in furtherance of the attempted robbery and that the killing occurred during the continuous sequence of events surrounding the attempted robbery.The court also rejected the defendant's claim of instructional error, as the trial court's instructions were legally proper and did not need to include a requirement for proving accessorial liability. Additionally, the court found that the defendant had waived his confrontation clause claim by not objecting to the admission of Rivera's video-recorded interviews at trial.Finally, the court declined to overrule its precedent in State v. Newsome, which allows a reliable out-of-court statement to serve as the sole evidentiary basis for a conviction. The court concluded that Rivera's statements were reliable and corroborated by other evidence, thus sufficient to establish the defendant's intent to commit attempted robbery.The judgment of the trial court was affirmed. View "State v. Hinton" on Justia Law

The plaintiff in error, Gregory Johnson, challenged his summary conviction of three counts of criminal contempt for repeatedly interrupting and directing racial slurs and other profanities at the court during his habeas corpus trial. He claimed that the trial court deprived him of his right to due process by not postponing the contempt proceeding and by not ordering it to be held before a different judge.The trial court, acting in the capacity of a trial court for the habeas proceeding, conducted the first day of the trial on April 4, 2023, and resumed on May 4, 2023. The plaintiff, appearing virtually, refused to comply with the court's instructions, used racial slurs, and swore at the court. The court warned the plaintiff multiple times before finding him in contempt. The court then appointed counsel for the plaintiff, allowed a private consultation, and provided an opportunity for both the plaintiff and his counsel to speak before sentencing.The Connecticut Supreme Court reviewed the case and found that the trial court's summary contempt proceeding substantially complied with the requirements of Practice Book § 1-16, which ensures fairness in the adjudication of summary criminal contempt. The court concluded that the plaintiff's behavior obstructed the orderly administration of justice, justifying the trial court's decision not to defer the proceeding under Practice Book § 1-17. The court also determined that the trial judge did not become personally embroiled in the controversy, as the judge maintained a calm demeanor and provided the plaintiff with multiple warnings and opportunities to explain his behavior.The court rejected the plaintiff's claim that his medical issues and alleged incompetency warranted deferral of the contempt proceeding. The trial court had observed the plaintiff's behavior and found him competent, and his counsel did not request a competency evaluation. The Connecticut Supreme Court dismissed the writ of error, upholding the trial court's findings and sentencing. View "Johnson v. Superior Court" on Justia Law

The defendant was convicted of manslaughter in the first degree with a firearm, criminal possession of a firearm, criminal possession of ammunition, and carrying a pistol without a permit. The incident involved the defendant shooting and killing a bystander while returning fire at an individual who had shot at him first. The defendant argued that the trial court improperly declined to instruct the jury on self-defense for the manslaughter charge and that his convictions for both criminal possession of a firearm and ammunition violated double jeopardy.The trial court instructed the jury on self-defense for the murder charge but not for the manslaughter charge. The jury found the defendant not guilty of murder but guilty of manslaughter in the first degree with a firearm. The court found the defendant guilty of the remaining charges in a bench trial.The Connecticut Supreme Court reviewed the case and concluded that the trial court erred in not providing a self-defense instruction for the manslaughter charge. The court held that self-defense is a justification defense applicable to reckless manslaughter, regardless of whether the victim is a bystander or the aggressor. The court emphasized that the jury should have been allowed to consider whether the defendant's actions were justified under the circumstances. The court also found that the trial court's failure to provide a self-defense instruction was not harmless beyond a reasonable doubt, as it was the sole issue in the case.Additionally, the court held that the defendant's conviction for both criminal possession of a firearm and criminal possession of ammunition violated double jeopardy. The court concluded that the legislature did not intend to treat the possession of a firearm and the ammunition within it as separate crimes when both are used during a single incident. Therefore, the court vacated the defendant's conviction for criminal possession of ammunition.The Connecticut Supreme Court reversed the conviction for manslaughter in the first degree with a firearm and remanded the case for a new trial on that charge. The court vacated the conviction for criminal possession of ammunition and affirmed the judgment in all other respects. View "State v. Williams" on Justia Law

The case involves a dispute between two former spouses regarding the interpretation of their separation agreement, which was incorporated into their dissolution judgment. The plaintiff sought modification of child support and alimony based on an alleged substantial change in the defendant's income, specifically his bonuses and profit sharing. The separation agreement included provisions for additional child support and alimony based on the defendant's bonuses and profit sharing, with a cap on gross earned income at $700,000 per year.The trial court found the relevant provisions of the separation agreement to be ambiguous and sided with the plaintiff's interpretation, which calculated additional child support and alimony based on the difference between the $700,000 cap and the defendant's base draw of $298,686. The court issued remedial orders for the defendant to pay arrearages and ongoing support based on this interpretation. The defendant appealed, arguing that the agreement unambiguously capped his total gross earned income at $700,000, beyond which no additional support was owed.The Appellate Court reversed the trial court's decision, concluding that the separation agreement unambiguously capped the defendant's total gross earned income at $700,000, thus relieving him of any obligation to pay additional child support and alimony if his income exceeded this amount. The Appellate Court remanded the case for recalculation of the defendant's obligations based on this interpretation.The Supreme Court of Connecticut reviewed the case and disagreed with the Appellate Court's conclusion. The Supreme Court found that the provisions of the separation agreement were ambiguous and that both parties' interpretations were plausible. The court held that the ambiguity required a factual determination of the parties' intent, necessitating a remand to the trial court for consideration of extrinsic evidence regarding the parties' intent at the time of the agreement's formation. The Supreme Court reversed the Appellate Court's judgment in part and remanded the case for further proceedings consistent with its opinion. View "Simpson v. Simpson" on Justia Law

The defendant was previously convicted of murder and criminal possession of a firearm. This court reversed the murder conviction due to the prosecutor's improper comments on the defendant's post-Miranda silence, violating Doyle v. Ohio. The defendant then moved to dismiss the murder charge, arguing that double jeopardy protections barred a retrial because the prosecutor intended to prevent an acquittal that was imminent without the impropriety.The trial court denied the motion to dismiss, finding that the defendant did not establish that the prosecutor intended to prevent an acquittal. The court based its decision on the trial transcripts and this court's previous decision, which concluded that the evidence was sufficient to support the conviction. The defendant appealed, renewing his argument that the double jeopardy clause barred a retrial and asserting that the Connecticut constitution provided broader protections.The Supreme Court of Connecticut affirmed the trial court's decision. The court held that the defendant failed to demonstrate that the prosecutor engaged in impropriety with the intent to prevent an acquittal that the prosecutor believed was imminent. The court noted that the evidence at trial, although not overwhelming, was sufficient to support a conviction, and the prosecutor's actions did not indicate an intent to provoke a mistrial or prevent an acquittal. The court also declined to overrule its previous decisions in State v. Colton and State v. Michael J., maintaining that the Connecticut constitution does not provide broader double jeopardy protections than the federal constitution. View "State v. Patrick M." on Justia Law

The case involves a dispute between two cotrustees of the William A. Rutherford Trust regarding the distribution of the trust estate following the deaths of the grantors, William and Joyce Rutherford. The plaintiff, Jeffrey A. Rutherford, and the defendant, Richard J. Slagle, could not agree on how the trust estate should be distributed. The defendant believed the trust required equal distribution among the decedent’s children, while the plaintiff disagreed.The defendant petitioned the Greenwich Probate Court to construe the trust and determine the proper distribution. The Probate Court granted the petition and ordered the trust estate to be distributed equally among the children. The plaintiff appealed this decree to the Superior Court, challenging the Probate Court’s decision and raising issues related to discovery in the Probate Court.The Superior Court granted the defendant’s motion for summary judgment, reasoning that the plaintiff’s reasons for appeal were limited to discovery issues and that there was no genuine issue of material fact regarding these issues. The plaintiff then appealed to the Connecticut Supreme Court, arguing that summary judgment is not appropriate in probate appeals and that the Superior Court failed to conduct a de novo review of the Probate Court’s decision.The Connecticut Supreme Court held that summary judgment is available in probate appeals under Practice Book § 17-44, as the term “any action” includes probate appeals. However, the court found that the Superior Court improperly granted summary judgment because it did not engage in a de novo review of the substantive issue resolved by the Probate Court—how the trust estate should be distributed. The Supreme Court reversed the judgment and remanded the case for further proceedings consistent with its opinion. View "Rutherford v. Slagle" on Justia Law

The plaintiff, a residential substance abuse treatment program operator, sought a special permit from the defendant, the Planning and Zoning Commission of the Town of Kent, to construct a greenhouse on its farm parcel. The plaintiff had been using the farm parcel for agricultural therapy as part of its treatment program, a use that became nonconforming after the town amended its zoning regulations in 2020 to prohibit privately operated clinics in rural residential districts. The commission denied the application, citing concerns that the greenhouse would impermissibly expand the nonconforming use by extending it from a seasonal to a year-round operation.The trial court upheld the commission's decision, dismissing the plaintiff's administrative appeal. The court found that the proposed greenhouse would indeed expand the nonconforming use, which was limited to the terms of the 2018 special permit and site plan approval. The court also noted that the commission's decision was consistent with the zoning regulations' intent to limit nonconforming uses.The Appellate Court reversed the trial court's judgment, concluding that the greenhouse was a permissible intensification of the nonconforming use. The court reasoned that the greenhouse would be located on land already used for agricultural therapy and would not change the nature, character, or kind of use involved. The court also found insufficient evidence to support the commission's concerns about adverse effects on the neighborhood.The Supreme Court of Connecticut reversed the Appellate Court's judgment, holding that the installation of the greenhouse would impermissibly expand the plaintiff's nonconforming use from seasonal to year-round. The court emphasized that extending a seasonal use into a year-round operation changes the character of the use, which is not permissible under zoning regulations. The case was remanded to the Appellate Court with direction to affirm the trial court's dismissal of the plaintiff's administrative appeal. View "High Watch Recovery Center, Inc. v. Planning & Zoning Commission" on Justia Law