Justia Criminal Law Opinion Summaries

The case revolves around a plaintiff who was arrested for operating a motor vehicle while under the influence of intoxicating liquor. The arresting officer prepared a report of the incident and mailed it to the Department of Motor Vehicles (DMV), but not within the three business days required by statute. At the plaintiff's license suspension hearing, the plaintiff's attorney objected to the admission of the report on the grounds that it was not prepared and mailed within the statutory timeframe. The hearing officer overruled the objection and admitted the report, which was the only evidence submitted at the hearing.The trial court dismissed the plaintiff's appeal, concluding that strict adherence to the preparation and mailing requirement was not necessary for the report to be admissible. The Appellate Court affirmed the trial court's judgment, concluding that the preparation and mailing requirement is directory, and therefore, strict compliance with that requirement is not necessary for a report to be admissible at a license suspension hearing.The Supreme Court of Connecticut reversed the Appellate Court's judgment. The court held that the hearing officer abused her discretion in admitting an incident report that did not strictly comply with the preparation and mailing provision of the statute in the absence of testimony from the arresting officer. The court concluded that the preparation and mailing requirement was mandatory because it promoted the accuracy and reliability of the information that would be used at a license suspension hearing. The court clarified that the statute describes substantive requirements that incident reports must meet, and the failure to meet those requirements renders a report inadmissible insofar as it fails to satisfy the exception for the report to be admitted without the need to produce the arresting officer at the suspension hearing. View "Marshall v. Commissioner of Motor Vehicles" on Justia Law

The defendant, Gonzalo Diaz, was convicted of felony murder, burglary in the first degree, conspiracy to commit burglary in the first degree, attempt to commit robbery in the first degree, and criminal possession of a firearm in connection with a shooting death. The defendant appealed, claiming that the trial court committed plain error by instructing the jury that it could consider his interest in the outcome of the trial when assessing his credibility. He also claimed that the prosecutor made improper remarks during his cross-examination and during rebuttal argument.The Superior Court in the judicial district of Waterbury found Diaz guilty of felony murder, manslaughter in the first degree with a firearm, burglary in the first degree, conspiracy to commit burglary in the first degree, and attempt to commit robbery in the first degree. The court also found him guilty of criminal possession of a firearm. The court later vacated the conviction for manslaughter in the first degree with a firearm.The Connecticut Supreme Court affirmed the lower court's decision. The court agreed that the trial court's instruction to the jury was erroneous, but it did not result in manifest injustice. The court also found that the prosecutor's remarks were not improper. The court concluded that the defendant failed to establish that the evidence adduced at trial, the disputed factual issues before the jury, and the instructions as a whole gave rise to the danger of juror misunderstanding or confusion. Therefore, the court affirmed the judgment of the trial court. View "State v. Diaz" on Justia Law

The defendant, Dwayne Sayles, was convicted of felony murder and conspiracy to commit robbery in the first degree, among other crimes, in connection with his role in the robbery of a convenience store and the shooting death of the store clerk. On appeal, Sayles challenged the trial court's denial of his motions to suppress evidence of his cell phone and the data contained therein. He argued that the police had violated his rights under Miranda and the Connecticut constitution when they continued to interrogate him after he had invoked his right to counsel, and that the seizure of his cell phone violated the fourth amendment to the U.S. constitution and the Connecticut constitution.However, the Supreme Court of Connecticut concluded that any error in the admission of the contents of Sayles' cell phone was harmless beyond a reasonable doubt due to the overwhelming wealth of evidence against him. This evidence included surveillance footage from inside of the convenience store, detailed testimony from a co-conspirator about Sayles' and his own involvement in the events, testimony from a jailhouse informant that Sayles had confessed to his involvement in the crimes, and a corroborating statement made to the police by a friend of Sayles. The court also noted significant evidence of Sayles' consciousness of guilt, such as testimony that he had directed his cousin to assault a potential witness to force him to recant his testimony. Physical evidence, including a ski mask and gloves found during the search of Sayles' residence and cell phone location data, further corroborated the testimony and statements. Given this, the court affirmed the Appellate Court’s judgment and declined to address Sayles' constitutional challenges. View "State v. Sayles" on Justia Law

In this case, the defendant, Lawrence Lee Henderson, was convicted of home invasion after a jury trial. During the trial, the defendant contracted COVID-19, resulting in a 25-day delay in jury deliberations. When the deliberations resumed, the jury found the defendant guilty of home invasion but not guilty of other charges and lesser included offenses.The defendant appealed, claiming that the court should reverse his conviction of home invasion or grant him a new trial on that charge because the jury’s verdicts of guilty of home invasion and not guilty of a lesser included offense were legally inconsistent. He also claimed that the trial court abused its discretion by failing to declare a mistrial when he contracted COVID-19, which resulted in the delay in jury deliberations.The court upheld the trial court’s decision, holding that legally inconsistent verdicts are unreviewable on appeal, following its precedent in State v. Arroyo, which was consistent with United States Supreme Court precedent and that of the majority of other jurisdictions. In terms of the COVID-19 delay, the court found that the trial court did not abuse its discretion in denying the defendant's motion for a mistrial, as the delay was unavoidable due to the pandemic, and the defendant failed to demonstrate actual prejudice from the delay. View "State v. Henderson" on Justia Law

The case involves a defendant who was convicted, after a jury trial, of burglary in the first degree, criminal mischief in the first degree, and threatening in the second degree, among other crimes. The defendant had unlawfully entered his brother's residence and caused significant damage within it. Upon appeal, the defendant argued that the trial court had committed plain error by not identifying the specific crime or crimes he allegedly intended to commit when he entered the residence during the jury instruction on first-degree burglary.However, the Supreme Court of Connecticut held that the Appellate Court correctly concluded that the trial court had not committed plain error. The trial court's instruction accurately recited the elements of the burglary charge and clarified that the intent to commit a crime within the building is a distinct element. Furthermore, the court noted that although it is the better practice for trial courts to name the crime or crimes and define such elements in its instructions, it has never been clearly held to be mandatory.Additionally, the court found that even if there was a patent error in the court’s instruction, the omission did not result in a manifest injustice. The evidence presented at trial established that the defendant had violently forced his way into the residence and caused extensive damage, which satisfied the intent element. View "State v. Kyle A." on Justia Law

In the State of Connecticut, the petitioner, who was convicted of felony murder and other crimes, filed a petition for a writ of habeas corpus in 2018, more than five years after his conviction was deemed final. The petitioner initially filed a timely habeas petition in 2012 but withdrew it due to dissatisfaction with his assigned counsel. When filing his 2018 habeas petition, the Commissioner of Correction moved for an order to show cause why the petition should not be dismissed as untimely under § 52-470 (c) and (e). The petitioner argued that good cause existed to excuse the untimely filing since his previous counsel had failed to inform him of the deadline to refile his petition. The habeas court dismissed the 2018 petition as untimely, a decision upheld by the Appellate Court.On appeal to the Supreme Court of Connecticut, the Court reversed the judgment of the Appellate Court, concluding that the habeas court’s determination that no good cause existed was based on a clearly erroneous factual finding. The Court found that the habeas court wrongly assumed that the petitioner's previous counsel had advised him to refile his habeas petition immediately after withdrawing the first one. The Court also clarified that, under the totality of the circumstances, ineffective assistance of counsel can be considered an external, objective factor that could establish good cause to excuse the late filing of a habeas petition under § 52-470 (c) and (e). The case was remanded for a new hearing and a good cause determination under § 52-470 (c) and (e) in light of its factual findings with respect to the performance of prior habeas counsel. View "Rose v. Commissioner of Correction" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of one count of sexual assault in the first degree and two counts of risk of injury to a child, holding that Defendant was not entitled to relief on his claims of error.On appeal, Defendant argued that the State infringed on his right to due process by providing an inadequate notice of intent to offer evidence of other sexual misconduct and that the trial court abused its discretion by admitting the testimony of his daughter concerning sexual misconduct he had engaged in with her fourteen years earlier. The Supreme Court affirmed, holding (1) Defendant had no constitutional right to pretrial notice of other sexual misconduct evidence; and (2) the trial court did not abuse its discretion by admitting evidence of Defendant's other sexual misconduct with his daughter. View "State v. Samuel U." on Justia Law

The Supreme Court affirmed the judgment of the appellate court concluding that the trial court lost jurisdiction when it dismissed Defendant's pending criminal charges and, therefore, was without jurisdiction to entertain the State's motion to open the judgment and reinstate the charges, holding that criminal courts do not have jurisdiction to open a judgment following a dismissal.After Defendant was charged with risk of injury to a child and breach of the peace in the second degree the court granted his application to participate in a supervised diversionary program for individuals with psychiatric disabilities. The trial court later dismissed the charges against him. The State moved to open the judgment of dismissal on the grounds that Defendant failed to satisfactorily complete the diversionary program. The trial court granted the motion on the grounds that the dismissal was erroneous. The appellate court reversed, concluding that the trial court lost jurisdiction over the matter when it rendered the judgment of dismissal. The Supreme Court affirmed, holding that the appellate court properly concluded that the trial court lacked jurisdiction to entertain the State's motion to open the judgment and reinstate the charges. View "State v. Butler" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the trial court finding Defendant guilty of manslaughter in the first degree, criminal possession of a firearm, and possession of a weapon in a motor vehicle, holding that the evidence was insufficient to support Defendant's conviction of possessing a weapon in a motor vehicle.Specifically, the Supreme Court held (1) any claimed error on the part of the trial court in violating Defendant's right to confront the witnesses against him under the Sixth Amendment by allowing the chief medical examiner to testify about the results of the victim's autopsy, which the chief medical examiner had not performed himself, was harmless; and (2) the evidence was insufficient to support Defendant's conviction of possessing a weapon in a vehicle in violation of Conn. Gen. Stat. 29-38(a). View "State v. Robles" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of one count of sexual assault in the first degree and two counts of risk of injury to a child, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Court held (1) the trial court did not err in admitting certain testimony pursuant to the constancy of accusation doctrine; (2) the trial court did not err in excluding impeachment evidence of pending criminal charges against the State's key witness; and (3) the first degree of sexual assault charge was not ambiguous and therefore did not violate Defendant's right to jury unanimity under the Sixth Amendment. View "State v. Velasquez-Mattos" on Justia Law