Justia Criminal Law Opinion Summaries

Articles Posted in Connecticut Supreme Court
by
The Supreme Court affirmed the judgment of the trial court convicting Defendant of murder, criminal attempt to commit robbery in the first degree, conspiracy to commit robbery in the first degree, and criminal possession of a firearm, holding that the trial court did not err in denying Defendant's motions to suppress.In his suppression motions, Defendant sought to suppress (1) the firearm and related evidence seized from his residence, which evidence he argued was discovered as a result of an unlawful search, and (2) the incriminating statements he made during an interrogation at the police station, claiming the statements were made involuntarily. The Supreme Court affirmed the denial of Defendant's motions to suppress, holding (1) the trial court properly Defendant's motion to suppress the evidence obtained during the search of his residence; and (2) Defendant's statements were voluntary, and the trial court properly admitted them into evidence at trial. View "State v. Griffin" on Justia Law

by
The Supreme Court affirmed the decision of the appellate court upholding the trial court's judgment of conviction in this case, holding that there was sufficient evidence for the jury to find Defendant guilty of murder.After his first two trials ended in mistrials after hung juries Defendant was convicted of murder. On appeal, Defendant argued that the jury lacked sufficient evidence to find him guilty of murder because the State failed to prove the manner, means, place, cause, and time of death. The appellate court affirmed. The Supreme Court affirmed, holding that the evidence supported Defendant's conviction of murder. View "State v. Richards" on Justia Law

by
The Supreme Court affirmed the judgment of the trial court convicting Defendant of one count of murder with special circumstances and imposing a mandatory sentence under Conn. Gen. Stat. 53a-35a(1)(B) of life imprisonment without the possibility of release, holding that there was no error in the proceedings below.Specifically, the Supreme Court held that the trial court (1) correctly instructed the jury on the "in the course of a single transaction" element of murder with special circumstances; (2) did not commit plain error by failing to provide the jury, sua sponte, with a special credibility instruction with respect to one of the State’s witnesses, who Defendant claimed was the actual perpetrator of the murders; and (3) did not violate Defendant's state and federal constitutional rights to counsel and to present a defense by precluding defense counsel from making a certain argument in closing argument. View "State v. Silva" on Justia Law

by
The Supreme Court reversed the order of the trial court requiring Defendant to submit both to an examination for sexually transmitted diseases pursuant to Conn. Gen. Stat. 54-102a(a) and to testing for human immunodeficiency virus (HIV) pursuant to section 54-102a(b), holding that the trial court erred.Defendant was charged with patronizing a prostitute who was the victim of human trafficking and conspiracy to commit trafficking in persons. The State subsequently filed a motion seeking a court order requiring Defendant to submit to the examination and testing at issue. Thereafter, several victims of Defendant's alleged misconduct filed similar motions. The trial court ordered Defendant to submit to the examination and testing. Defendant appealed. The Supreme Court reversed, holding (1) under Conn. Const. art. I, 7, the trial court must make a finding that either an examination pursuant to section 54-102a(a) or testing pursuant to section 54-102a(b), or both, would provide would provide useful, practical information; and (2) because the trial court did not apply this standard, the case must be remanded for a new hearing. View "State v. Bemer" on Justia Law

by
The Supreme Court affirmed the judgment of the appellate court affirming Defendant's convictions of three distinct crimes in connection with his attack on a single victim over the course of an eight-hour period on a single day, holding that there was no error.Defendant was convicted of assault in the third degree, unlawful restraint in the first degree, and strangulation in the second degree. On appeal, Defendant argued that his constitutional right to a jury trial was violated when the trial court, rather than the jury, determined that the charges of assault and unlawful restraint were not "upon the same incident" as that giving rise to the charge of strangulation. The appellate court affirmed. The Supreme Court affirmed, holding that the trial court's determination at sentencing that the offenses of strangulation, assault, and unlawful restraint were not "upon the same incident" did not implicate the constitutional principles underlying Apprendi v. New Jersey, 530 U.S. 490 (2000), or double jeopardy concerns. View "State v. Watson" on Justia Law

by
The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the trial court convicting Defendant of one count of intentional assault and one count of reckless assault, holding that the appellate court correctly concluded that the jury's verdicts of guilty of intentional assault and reckless assault were not legally erroneous.On appeal, Defendant argued that the verdicts finding him guilty of intentional assault and reckless assault were legally inconsistent because their requisite mental states of intentional and reckless were mutually exclusive. The appellate court concluded that the convictions were consistent because each mental state pertains to a different result. The Supreme Court affirmed, holding that the jury reasonably could have found that Defendant intended to cause the victim serious physical injury and simultaneously disregarded the risk that his conduct would cause the victim's death. View "State v. Alicea" on Justia Law

by
The Supreme Court affirmed Defendant's conviction of two counts of sexual assault in the first degree and two counts of risk of injury to a child, holding that there was no error in the proceedings below.On appeal, Defendant asserted that the trial court erred in admitting evidence of the victim's out-of-court demeanor and that the prosecutor made improper remarks during rebuttal and closing argument. The Supreme Court affirmed, holding (1) the allegedly improper admission of the victim's demeanor testimony was harmless; and (2) two of the prosecutor's remarks made during closing argument and rebuttal were improper, but these improprieties did not deprive Defendant of a fair trial. View "State v. Courtney G." on Justia Law

by
The Supreme Court reversed the judgment of the habeas court denying Petitioner's amended petition for a writ of habeas corpus, holding that Petitioner's classification as a sex offender violated his right to procedural due process under both the federal constitution and Conn. Const. art. I, 9.In his habeas corpus petition, Petitioner alleged that the Commissioner of Correction violated his right to procedural due process in classifying him as a sex offender and that the habeas court erred in determining that the challenged classification did not violate his right to substantive due process or his right not to be punished "except in cases clearly warranted by law," under article first, section nine. The Supreme Court reversed, holding that Petitioner's classification as a sex offender violated his right to procedural due process. View "Anthony A. v. Commissioner of Correction" on Justia Law

by
The Supreme Court reversed the judgment of the appellate court affirming Defendant's conviction of risk of injury to a child, holding that the trial court abused its discretion by limiting Defendant's direct examination of himself and that the error was harmful.During trial, Defendant represented himself. On appeal, Defendant argued that the trial court erred in excluding testimony pertaining to his justification defense. The appellate court affirmed the convictions. The Supreme Court reversed, holding that the trial court abused its discretion in precluding Defendant's testimony, in which he attempted to testify about information crucial to his justification defense, and that the error was harmful. View "State v. Mark T." on Justia Law

by
The Supreme Court affirmed the judgment of the appellate court affirming Defendant's conviction of murder and related offenses, holding that the appellate court correctly concluded that the trial court's rejection of Defendant's insanity defense was reasonable.On appeal, Defendant argued that the trial court improperly rejected the opinions of his experts. Specifically, Defendant argued that the State neither presented nor elicited evidence to undermine the consensus of his experts that, as the result of a mental disease, Defendant lacked substantial capacity to control his conduct within the requirements of the law. The appellate court affirmed. The Supreme Court affirmed, holding that the appellate court did not err in concluding that the trial court's rejection of his expert opinion was not arbitrary. View "State v. Weathers" on Justia Law