Justia Criminal Law Opinion Summaries

The Supreme Court affirmed the judgment of the habeas court denying in part Petitioner's petition for a writ of habeas corpus, holding that the habeas court correctly concluded that Petitioner did not demonstrate that he had suffered prejudice from the ineffective assistance of his trial counsel.Petitioner, a citizen of Jamaica who held a valid green card, pleaded guilty, pursuant to the Alford doctrine, to risk of injury to a child and strangulation in the third degree. The federal government subsequently initiated removal proceedings against Petitioner based, in part, on his conviction of risk of injury to a child. Petitioner filed a petition for a writ of habeas corpus, alleging ineffective assistance of counsel alleging that he would have gone to trial had his trial counsel not performed deficiently. The habeas court denied the petition as to the claim at issue in this appeal. The Supreme Court affirmed, holding that Petitioner did not meet his burden of establishing that there was a reasonable probability that he would have rejected the plea offer and proceeded to trial. View "Grant v. Commissioner of Correction" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of felony murder and other crimes, holding that there was no error or abuse of discretion in the proceedings below.Specifically, the Supreme Court held that the trial court (1) Defendant failed to establish under the third prong of State v. Golding, 567 A.2d 823 (Conn. 1989), that the trial court violated his federal due process rights by detaining three eyewitnesses to secure their attendance at trial; and (2) did not abuse its discretion by permitting the prosecutor to read passages from the witnesses' grand jury transcripts to the jury for substantive purposes pursuant to State v. Whelan, 513 A.2d 86 (Conn. 1986). View "State v. Gray" on Justia Law

The Supreme Court reversed the judgment of the appellate court reversing the judgments of the trial court revoking Defendant's probation pursuant to Conn. Gen. Stat. 53a.32, holding that Defendant's conduct leading to the revocation was not entitled to First Amendment protection.After an escalated emotional confrontation with the staff of his child's preschool the trial court found that the State had met its burden of proving, by a preponderance of the evidence, that Defendant had violated the standard terms of his probation by violating Conn. Gen. Stat. 53a-181(a). On appeal, Defendant argued that his remarks warranted First Amendment protection because the State's evidence was insufficient to establish that his remarks constituted a true threat. The appellate court agreed and reversed. The Supreme Court reversed, holding that the appellate court erred in concluding that Defendant's remarks warranted First Amendment protection. View "State v. Taveras" on Justia Law

The Supreme Court reversed in part the judgment of the appellate court reversing Defendant's convictions for intentional manslaughter, reckless manslaughter, and criminally negligent operation of a motor vehicle, holding that the appellate court improperly ordered a new trial on all three charges.At the sentencing hearing, the trial court vacated Defendant's intentional manslaughter conviction pursuant to State v. Polanco, 61 A.3d 1084 (Conn. 2013), and rendered judgment on the remaining counts of conviction. The appellate court concluded that Defendant's convictions for reckless manslaughter and criminally negligent operation were legally inconsistent but that neither reckless manslaughter nor criminal negligent operation was inconsistent with intentional manslaughter. The court then remanded the case for a new trial on all charges. The Supreme Court reversed in part, holding that the appellate court should have reinstated Defendant's intentional manslaughter conviction. View "State v. Daniels" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of sexual assault in the first and fourth degree, attempt to commit 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 argued (1) the trial court erred in overruling his objection brought pursuant to Batson v. Kentucky, 476 U.S. 79 (1986), objecting to the prosecutor's exercise of peremptory challenges to two prospective members of the jury; and (2) his conviction for risk of injury to a child violated constitutional double jeopardy protections. The Supreme Court affirmed, holding (1) the trial court did not commit clear error in determining that Defendant failed to meet his burden of proving by a preponderance of the evidence that the jury selection process in his case was tainted by purposeful discrimination; and (2) Defendant's conviction for two counts of risk of injury did not violate his right to be free from double jeopardy. View "State v. Jose A.B." on Justia Law

The Supreme Court affirmed the judgment of the appellate court concluding that Defendant's confrontation rights were not violated by the admission into evidence of a codefendant's dual inculpatory statement to a fellow inmate acting at the behest of the state police, holding that there was no error.Defendant was convicted by a jury of murder, home invasion, burglary, and other crimes. The appellate court affirmed. At issue before the Supreme Court was whether the appellate court correctly concluded that the admission of the codefendant's dual inculpatory statement did not violate Defendant's confrontation rights under either the United States or Connecticut constitutions. The Supreme Court affirmed, holding that there was no error in the proceedings below. View "State v. Patel" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of two counts of assault in the second degree, holding that the trial court did not commit reversible error.Specifically, the Supreme Court held (1) there was sufficient evidence to sustain the jury’s verdict of guilty of assault in the second degree; (2) the trial court did not err in denying Defendant’s request to cross-examine the victim more extensively regarding her pending civil action against Defendant arising out of the same incident; and (3) the trial court did not abuse its discretion in allowing a paramedic, testifying as a fact witness, to testify regarding symptoms of a concussion. View "State v. Fisher" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of murder and criminal possession of a pistol or revolver, holding that any error in the proceedings below was harmless.Specifically, the Supreme Court held (1) the trial court acted within its discretion in admitting testimony from four lay witnesses identifying Defendant in video surveillance footage; (2) the trial court properly admitted expert testimony regarding an enhancement of the video surveillance footage, and any error in the court's conclusion that defense counsel had opened the door to certain testimony elicited during the prosecutor’s redirect examination of the expert was harmless; (3) the trial court properly denied Defendant’s request for a special credibility instruction as to a witness whom Defendant claimed should have been treated as a jailhouse informant; (4) any error in the trial court's admission of identifications of Defendant made by Nigel Watts was harmless; and (5) there was sufficient evidence to support Defendant's conviction for criminal possession of a pistol or revolver. View "State v. Bruny" on Justia Law

The Supreme Court amended section 7-3(a) to the Connecticut Code of Evidence to incorporate an exception for testimony relating to the identification of persons depicted in surveillance video or photographs and affirmed the judgment of the trial court in this case, holding that the amendment did not affect the result in this appeal.After a jury trial, Defendant was found guilty of murder and criminal possession of a firearm. At issue on appeal was the wisdom of the "ultimate issue rule" as applied to lay witness identifications of persons depicted in video surveillance footage. The Supreme Court affirmed Defendant's convictions, holding (1) section 7-3(a) of the Connecticut Code of Evidence is hereby amended to incorporate an exception to the ultimate issue rule for lay opinion testimony that relates to the identification of persons depicted in surveillance video or photographs; (2) State v. Finan, 881 A.2d 187 (Conn. 2005), is hereby overruled; and (3) this Court adopts a totality of the circumstances test for determining whether lay opinion testimony identifying a person in surveillance video or photographs is admissible. View "State v. Gore" on Justia Law

The Supreme Court reversed the judgment of the trial court denying Defendant's motion to correct an illegal sentence, holding that the trial court abused its discretion by denying Defendant's motion to correct.Defendant, a juvenile offender, was convicted of two counts each of kidnapping in the first degree and sexual assault in the first degree, among other offenses. The sentencing court imposed a total effective sentence of sixty years of incarceration. Relying on later changes to juvenile sentencing law, Defendant filed a motion to correct an illegal sentence. The trial court rejected Defendant's claims. The Supreme Court reversed, holding (1) the sentencing court substantially relied on a materially false and unreliable theory; and (2) therefore, Defendant's sentence was imposed in an illegal manner in violation of his right to due process, and the trial court erred in denying Defendant's motion to correct. View "State v. Belcher" on Justia Law