Justia Criminal Law 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

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 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 the judgment of the trial court convicting Defendant of four counts of patronizing a prostitute and one count of trafficking in persons as an accessory, holding that the state presented insufficient evidence to convict Defendant of any of the charged counts.On appeal, Defendant claimed, among other things, that the state presented insufficient evidence for a reasonable jury to have concluded that he knew or reasonably should have known that the men with whom he engaged in sexual conduct for a fee were victims of trafficking. The Supreme Court reversed, holding (1) there was insufficient evidence to convict Defendant of the crime of patronizing a prostitution; and (2) the evidence was insufficient to prove Defendant was guilty of the crime of trafficking in persons as an accessory because the state did not prove that he had the specific intent necessary for accessorial liability for the crime of trafficking in persons. View "State v. Bemer" on Justia Law

The Supreme Court affirmed Defendant's conviction of two counts of murder, holding that Defendant was entitled to relief on her argument that no rational finder of fact reasonably could have rejected her insanity defense on the present factual records.Specifically, the Supreme Court held that the trier of fact reasonably credited the State's expert testimony presented to rebut Defendant's insanity defense that, at the time Defendant murdered her two children, she was not suffering from a mental disease or defect, was able to appreciate the wrongfulness of her conduct, and was able to conform her conduct to the requirements of law. View "State v. LeRoya M." on Justia Law

The Supreme Court reversed the judgment of the appellate court affirming Defendant's conviction, holding that the warrantless canine sniff conducted by law enforcement officers of the exterior door to a motel room for the purpose of detecting the presence of illegal drugs inside the room violated the warrant requirement of Conn. Const. Art. I, 7.After Defendant was charged with several drug-related offenses he filed a motion to suppress the evidence that had been seized from his motel room pursuant to a search warrant. The trial court denied the motion. Thereafter, Defendant entered a conditional plea of solo contenders. The appellate court affirmed. The Supreme Court reversed, holding that the appellate court erred in concluding (1) the canine sniff was not a search that violated Defendant's rights under article 1, section 7; and (2) the visual sweep of Defendant's motel room was justified by the exigencies of the situation. The Court remanded the case for further proceedings. View "State v. Correa" on Justia Law

The Supreme Court affirmed Defendant's conviction of murder and carrying a pistol without a permit, holding that while evidence regarding a defendant's gang affiliation may prejudice a jury against a defendant, there was no prejudicial error in this case.On appeal, Defendant argued that the trial court erred in admitting certain evidence, including police photographs arguably reflecting Defendant's gang membership. The Supreme Court affirmed, holding (1) any error in the trial court's admission of expert testimony regarding local street gangs was harmless beyond a reasonable doubt; (2) the trial court did not abuse its discretion in admitting the photographs at issue; and (3) Defendant's remaining evidentiary arguments were unavailing. View "State v. Tomlinson" on Justia Law