Justia Criminal Law Opinion Summaries

The Supreme Court affirmed the judgment of the appellate court reversing the judgment of the habeas court denying Appellant's petition for a writ of habeas corpus and ordering a new trial on certain charges, holding that the trial court committed an error under State v. Salomon, 949 A.2d 1092 (Conn. 2008), and that the error was not harmless.At issue in this appeal and the companion case decided today, see Banks v. Commissioner of Correction, __ A.3d __ (Conn. 2021), was how the harmlessness of a Salamon error is to be assessed. In Salamon, the Supreme Court held that, when a defendant is charged with kidnapping in conjunction with another underlying crime, the defendant is entitled to a jury instruction that he cannot be convicted of kidnapping if the restraint imposed on the victim was merely incidental or necessary to the underlying crime. Here, Appellant forcibly moved and restrained his victims after having taken property in their possession. The Supreme Court affirmed the judgment of the appellate court granting Appellant's habeas petition and ordering a new trial on the kidnapping charges, holding that this Court had no fair assurance that the Salamon error in this case did not have a substantial and injurious effect or influence in determining the jury's verdict. View "Bell v. Commissioner of Correction" on Justia Law

In this case, the Supreme Court resolved two questions left open by State v. Salamon, 949 A.2d 1092 (Conn. 2008) and its progeny, holding that that standard articulated in Brecht v. Abrahamson, 507 U.S. 6019 (1993), which governs federal habeas actions, applies in state habeas proceedings as well.In Salamon, the Supreme Court overruled its longstanding interpretation of Connecticut's kidnapping statutes and held that, when a defendant is charged with kidnapping in conjunction with another underlying crime, the defendant is entitled to a jury instruction that he cannot be convicted of kidnapping if the restraint imposed on the victim was merely incidental or necessary to the underlying crime. In the instant case, Appellant was found guilty of four counts of kidnapping in the first degree and four counts of robbery. After the Supreme Court decided Salamon, Appellant filed a petition for a writ of habeas corpus arguing that the instructions given to the jury were not in accordance with Salamon. The habeas court denied the petition. The appellate court reversed. The Supreme Court affirmed, holding (1) the Brecht standard applied in this case; and (2) the habeas court correctly determined that the trial court's failure to instruct Appellant's jury in accordance with Salamon was harmless. View "Banks v. Commissioner of Correction" on Justia Law

The Supreme Court affirmed Defendant's conviction of two counts of interfering with an officer, in violation of Conn. Gen. Stat. 53a-167a(a), holding that there was no error in the proceedings below.At issue on appeal was whether the trial court erred in denying Defendant's pretrial motion to suppress on the grounds that he was seized in violation of the Fourth Amendment when a marked police cruiser blocked the egress of his vehicle, which was parked with its engine running and Defendant asleep in the driver's seat. The Supreme Court affirmed, holding that no violation of the Fourth Amendment occurred because the responding officer was checking on Defendant's well-being pursuant to the officer's community caretaking function and was not engaged in an investigatory stop involving criminal activity. View "State v. Pompei" on Justia Law

The Supreme Court affirmed Defendant's conviction of three counts of first degree sexual assault and three counts of risk of injury to a child, holding that there was no error in the proceedings below.Specifically, the Supreme Court held (1) the prosecutor did not engage in prosecutorial impropriety in her questioning of the victim; (2) the prosecutor did not engage in prosecutorial impropriety during closing and rebuttal arguments; and (3) the trial court did not violate Conn. Gen. Stat. 54-84(b) or infringe on Defendant's constitutional right to remain silent when it denied his request to instruct the jury that he elected not to testify and instead referred to his failure to testify. View "State v. Michael T." on Justia Law

The Supreme Court affirmed the judgment of the appellate court affirming the trial court's denial of Defendant's motion to correct an illegal sentence, holding that the trial court properly denied the motion.Defendant was convicted of murder and sentenced to fifty years of incarceration. In his motion to correct an illegal sentence, Defendant argued that the sentencing court substantially relied on materially inaccurate information concerning both his criminal history and the particular manner in which he committed the criminal offense. The trial court denied the motion, and the appellate court affirmed. The Supreme Court affirmed, holding that the appellate court correctly concluded that the trial court did not abuse its discretion in denying Defendant's motion to correct an illegal sentence. View "State v. Francis" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of six counts of capital felony, among other crimes, holding that Connecticut's individual voir dire process protected Defendant's right to a fair trial by assessing and mitigating the prejudicial effects of pretrial publicity about this notorious case.The State charged Defendant with six counts of capital felony, three counts of murder, four counts of kidnapping, and other crimes. Following extensive pretrial motions practice, Defendant's case was tried to a jury, which returned a guilty verdict on all counts. The trial court subsequently sentenced Defendant to six consecutive death sentences. On appeal, Defendant claimed, among other allegations of error, that the trial court improperly denied his motion to change the venue of his trial given the effects of prejudicial pretrial publicity. The Supreme Court affirmed, holding (1) the pretrial publicity did not result in actual jury prejudice that deprived Defendant of a fair trial; and (2) Defendant was not entitled to relief on his remaining allegations of error. View "State v. Komisarjevsky" on Justia Law

The Supreme Court remanded this case to the trial court for further proceedings, holding that the trial court erred by failing to inquire into defense counsel's alleged conflict of interest.Defendant was convicted of one count of murder and sentenced to fifty years of imprisonment. On appeal, Defendant argued that his federal constitutional right to the effective assistance of counsel was violated during trial when the court denied his motions to dismiss his counsel without adequately inquiring into certain bases for his motions and when the court failed to conduct any inquiry into defense counsel's alleged conflict of interest. The Supreme Court affirmed, holding that the trial court inadequately inquired into the bases for Defendant's motions to dismiss defense counsel. View "State v. Davis" on Justia Law

The Supreme Court affirmed the judgment of the appellate court affirming Defendant's conviction of murder as either a principal or as an accessory, holding that Defendant was not entitled to relief on any of his allegations of error.On appeal, Defendant argued that the appellate court abused its discretion by denying him permission to file a supplemental brief to raise a new claim pursuant to Carpenter v. United States, __ U.S. __ (2018) and incorrectly determined that his hearsay claim regarding the testimony of a key state witness was unpreserved. The Supreme Court affirmed, holding (1) the appellate court should have granted Defendant's motion to file a supplemental brief, but any error was harmless; and (2) the trial court properly admitted the challenged testimony as nonhearsay and, alternatively, any error was harmless. View "State v. Armadore" on Justia Law

The Supreme Court reversed the sentence imposed upon Defendant in connection with his conviction of four counts of sexual assault in the first degree and three counts of risk of injury to a child, holding that the trial court improperly sentenced Defendant to a period of probation on each count of sexual assault, in violation of Conn. Gen. Stat. 53a-29(a).After a jury trial, Defendant was found guilty of sexually abusing his daughter. The trial court sentenced Defendant to twenty-five years of imprisonment, execution suspended after twenty years, and ten years of probation on each count of sexual assault and ten years of imprisonment on each count of risk of injury to a child. The sentences were imposed concurrently. The Supreme Court affirmed the convictions but reversed the sentence, holding (1) the trial court improperly imposed a period of probation on each of Defendant's four sexual assault convictions; and (2) Defendant's challenges to his conviction failed. View "State v. Jose R." on Justia Law

The Supreme Court affirmed the judgment of the appellate court affirming the decision of the trial court dismissing Plaintiff's declaratory judgment action for lack of subject matter jurisdiction, holding that the appellate court properly upheld the trial court's dismissal of the action as not ripe.Plaintiff, who was convicted of murder, has been incarcerated since 1990. Plaintiff brought this action seeking a judgment declaring that Conn. Gen. Stat. 54-125g was applicable to him and that the commissioner must factor his eligibility for early release in his time sheet. The trial court concluded that the issue raised by Plaintiff was not ripe. The appellate court affirmed. The Supreme Court affirmed, holding that Plaintiff's claims were nonjusticiable and that the trial court lacked subject matter jurisdiction on this alternative ground. View "Francis v. Board of Pardons & Paroles" on Justia Law