Justia Connecticut Supreme Court Opinion Summaries

Defendant was convicted of kidnapping in the second degree and interfering with an officer. On appeal, Defendant argued, among other claims, that the trial court improperly denied him his right to self-representation because the denial was based on incorrect grounds - the adequacy of defense counsel. The Appellate Court agreed and reversed, concluding that the trial court’s denial of Defendant’s motion to proceed pro se was improper and that the improper ruling was structural error. The Supreme Court affirmed, holding (1) the trial court’s denial of Defendant’s request to represent himself was clear and conclusive, and therefore, Defendant’s subsequent conduct did not effect a waiver of his right to self-representation; and (2) the trial court’s denial of Defendant’s request was improper, and the improper denial of the request was structural error. View "State v. Braswell" on Justia Law

Plaintiffs, the Department of Mental Health and Addiction Services and its Freedom of Information Officer, received a request under the Freedom of Information Act from Ron Robillard for records concerning Amy Archer Gillian, who was convicted of second degree murder for the arsenic poisoning of a resident of her nursing home. Plaintiffs disclosed some, but not all, of the requested records. The Freedom of Information Commission determined that Gilligan’s medical and dental records were not exempt from disclosure. The trial court sustained Plaintiffs’ appeal as to those records. The Supreme Court reversed, holding (1) Plaintiffs had standing to appeal the decision of the Commission; and (2) the documents at issue were medical records related to the diagnosis and treatment of a patient and were, therefore, psychiatric records exempt from disclosure pursuant to Conn. Gen. Stat. 52-146e. View "Freedom of Info. Officer, Dep’t of Mental Health & Addiction Servs. v. Freedom of Info. Comm’n" on Justia Law

Plaintiffs manufactured industrial ball bearings, and Defendant was Plaintiffs’ exclusive distributor for certain Nice Ball Bearings, Inc. products. Plaintiffs brought this action for Defendant’s failure to meet its contractual obligations under an agreement between the parties and for Defendant’s anticipatory breach of contract. The trial court ruled in favor of Defendant on Plaintiffs’ claims, finding that Plaintiffs had waived a contractual requirement that Defendant purchase a minimum dollar value of bearings from Plaintiffs each year. The Appellate Court reversed, concluding that, even if Plaintiffs had waived the minimum purchase requirement as to certain years of the contract, the trial court clearly erred in finding that the waiver continued into subsequent contract years. The Supreme Court reversed in part, holding that the record contained sufficient evidence to support the trial court’s finding that Plaintiffs waived the minimum purchase requirement on a continuing basis. Remanded. View "RBC Nice Bearings, Inc. v. SKF USA, Inc." on Justia Law

After a jury trial, Defendant was convicted of larceny in the first degree and conspiracy to commit larceny in the first degree. The convictions were based in part on evidence that included warrantless recordings of telephone conversations between Defendant and Jacqueline Becker, which were recorded without Defendant’s consent but with the consent of Becker. The Supreme Court affirmed the convictions, holding (1) recording a telephone conversation with the consent of one party to that conversation does not violate the prohibition on unreasonable searches and seizures under the Connecticut Constitution; and (2) the trial court’s failure to conduct an independent inquiry regarding Defendant’s competence to stand trial was not improper. View "State v. Skok" on Justia Law

Defendant was charged in separate informations with the murders of Rene Pellegrino and Michelle Comeau. The trial court granted the State’s motion to consolidate the cases based on the cross admissibility of the evidence. After a joint trial of both the Comeau and Pellegrino cases, the jury found Defendant guilty of the Pellegrino murder but was unable to reach a verdict in the Comeau case. The trial court rendered judgment in accordance with the jury verdict in the Pellegrino case and declared a mistrial in the Comeau case. On appeal from the judgment of conviction in the Pellegrino case, Defendant claimed that the trial court abused its discretion consolidating the cases for trial. The Supreme Court affirmed, holding that the trial court did not abuse its discretion in consolidating the Pellegrino and Comeau cases for trial on the basis of the cross admissibility of the evidence in the two cases. View "State v. Anderson" on Justia Law

At issue in this case was Connecticut’s debt negotiation statutes, Conn. Gen. Stat. 36a-671 through 36a-671e, which authorize the Banking Commissioner to license and regulate persons engaged in the debt negotiation. Plaintiff, a national consumer advocate law firm, petitioned the Commissioner for a declaratory ruling stating that Plaintiff qualified for exemption from the debt negotiation statutes under the attorney exception. This exception exempts only those attorneys admitted to the practice of law in Connecticut who engage or offer to engage in debt negotiation as an ancillary matter to the attorneys’ presentation of a client. The Commissioner concluded that Plaintiff did not qualify for exemption. The superior court affirmed. The Supreme Court reversed, holding that the debt negotiation statutes impermissibly intrude on the Judicial Branch’s exclusive authority to regulate attorney conduct and licensure and, therefore, violate the separation of powers provision contained in article II of the state Constitution. View "Persels & Assocs., LLC v. Banking Comm’r" on Justia Law

After a jury trial, Defendant was convicted of assault in the second degree and attempt to commit assault in the first degree. Defendant appealed, asserting that the trial court erred in its instructions to the jury. The Supreme Court affirmed, holding (1) the trial court correctly charged the jury on the subjective portion of the subjective-objective test for determining entitlement to self-defense; (2) the trial court properly charged the jury that Defendant was required to demonstrate that she had actual knowledge, rather than merely a reasonable belief, that the victim had violated the terms of their mutual combat by agreement; and (3) the jury instructions properly articulated the State’s burden of proof with respect to self-defense generally and combat by agreement specifically. View "State v. O'Bryan" on Justia Law

After a trial, the trial court terminated Respondent’s parental rights to his minor child and appointed the Commissioner of Children and Families as the child’s statutory parent. The Appellate Court affirmed. The Supreme Court affirmed, holding (1) Respondent had notice of all the steps court-ordered specific steps with which he was required to comply, and the trial court did not rely on conduct not within the scope of the steps when concluding that Respondent failed to rehabilitate; (2) there was sufficient evidence to support a finding that Respondent had failed to achieve sufficient rehabilitation to be able to parent his son within a reasonable amount of time; and (3) the trial court properly drew an adverse inference from Respondent’s refusal to submit to a drug test. View "In re Shane M." on Justia Law

After a jury trial, Defendant was convicted of murder, kidnapping in the second degree, and felony murder. The Supreme Court affirmed, holding (1) the prosecutor engaged in impropriety during the cross-examination of Defendant’s expert witness, but the instances of impropriety did not violate Defendant’s right to a fair trial and, therefore, did not warrant reversal of his conviction; (2) the trial court did not err in denying Defendant’s motions for a mistrial based on the improper presentation of uncharged misconduct evidence; (3) the evidence was sufficient to support Defendant’s kidnapping conviction; and (4) the trial court did not err in precluding that testimony of two witnesses on the basis of hearsay and relevance. View "State v. O'Brien-Veader" on Justia Law

After a jury trial, Defendant was convicted of murder. The Supreme Court affirmed, holding (1) Defendant did not preserve his claim that the trial court had an obligation to provide, sua sponte, a jury instruction on the risk of misidentification by an eyewitness pursuant to State v. Ledbetter; (2) the trial court did not abuse its discretion in the manner in which it conducted its inquiry into the allegation of juror bias; and (3) Defendant’s exclusion from the hearing concerning possible juror bias was not a violation of his constitutional rights to be present at a critical stage of the proceedings, to counsel, and to be presumed innocent. View "State v. Dixon" on Justia Law