Justia Criminal Law Opinion Summaries

The petitioner, who had previously been convicted of robbery in the first degree following a guilty plea, filed a habeas petition in 2018 challenging that conviction on the grounds of ineffective assistance of trial counsel. In 2020, the petitioner was deported to Jamaica. After deportation, his habeas counsel was unable to contact him or his family members. In early 2021, the habeas court scheduled a hearing to consider dismissing the petition due to the petitioner’s failure to appear and prosecute the case with due diligence. Following the hearing, the court dismissed the habeas petition for lack of prosecution.Approximately fifteen months after the dismissal, the petitioner filed a motion to open the judgment, arguing that he had not received notice of the hearing and that his counsel had failed to make reasonable efforts to notify him or communicate effectively. The Superior Court denied the motion, finding that the petitioner had not established a recognized basis for opening the judgment beyond the four-month period prescribed by Connecticut General Statutes § 52-212a. The petitioner appealed, and the Connecticut Appellate Court reversed, holding that a claim of ineffective assistance of habeas counsel was sufficient to invoke the habeas court’s common-law authority to grant a late motion to open a judgment.On further appeal, the Supreme Court of Connecticut reviewed whether ineffective assistance of habeas counsel could serve as a common-law exception to the four-month deadline in § 52-212a. The Supreme Court held that the phrase “unless otherwise provided by law” in § 52-212a does not include a new judicially created common-law exception for ineffective assistance of habeas counsel. The Court reasoned that such an exception would conflict with the statutory scheme governing habeas corpus, including requirements for expedient resolution and custody status. The Supreme Court reversed the Appellate Court’s judgment and directed affirmation of the habeas court’s denial of the motion to open. View "Clue v. Commissioner of Correction" on Justia Law

In 1997, an individual diagnosed with schizophrenia and alcohol use disorder attacked his father, resulting in serious injuries. He was charged with several offenses, including attempted murder and first-degree assault. At trial, he was found not guilty by reason of mental disease or defect and was committed to the custody of the Psychiatric Security Review Board for up to twenty years. Over the years, his commitment was extended multiple times, sometimes by agreement and sometimes after evidentiary hearings, based on findings that he remained a danger to himself or others. His condition improved over time, leading to less restrictive placements and eventual conditional release into the community, though he experienced a setback in 2020 that led to brief rehospitalization.After the expiration of his initial commitment, the state repeatedly sought and obtained extensions of his commitment. In 2022, the state filed another petition to extend his commitment. The acquittee moved to dismiss, arguing that the statutory commitment procedure violated his constitutional right to equal protection. The Superior Court, Judicial District of Middlesex, denied the motion and, after a hearing, found clear and convincing evidence that he remained dangerous, extending his commitment for two more years, until March 2025. The acquittee appealed, and the Connecticut Supreme Court granted transfer of the appeal.While the appeal was pending, the state filed a new petition to extend the commitment beyond 2025. The Board, however, found the acquittee was no longer dangerous and recommended denial of the petition. The state withdrew its petition, resulting in the acquittee’s discharge in March 2025. The Connecticut Supreme Court held that the appeal was moot because the acquittee had been released and no practical relief could be granted. The Court found neither the collateral consequences doctrine nor the “capable of repetition, yet evading review” exception applied. However, to avoid any lingering effects, the Court vacated the 2023 commitment order. View "State v. Guild" on Justia Law

A man was found not guilty by reason of mental disease or defect for several violent offenses, including first-degree burglary, risk of injury to a child, third-degree assault, and possession of a weapon on school grounds. He was committed to the jurisdiction of the Psychiatric Security Review Board in 2003 for up to ten years. His commitment was extended several times by agreement, but in 2018, he was granted conditional release and began living in the community under strict conditions related to his mental health treatment. In 2019, the state petitioned to extend his commitment, arguing that his discharge would pose a danger to himself or others.The Superior Court, judicial district of Stamford-Norwalk, denied the acquittee’s motion to dismiss the petition, which had argued that the recommitment procedure violated his federal equal protection rights. The court found, by clear and convincing evidence, that he continued to suffer from a psychiatric illness and posed a danger if released without supervision, and extended his commitment. The Appellate Court affirmed, holding that the recommitment scheme did not violate equal protection and that the trial court’s finding of dangerousness was not clearly erroneous.The Connecticut Supreme Court reviewed the case. It held that individuals found not guilty by reason of insanity and subject to recommitment are not similarly situated to civilly committed inmates for equal protection purposes, because the former’s commitment is based on a judicial finding that their criminal acts were caused by mental illness, while civilly committed inmates may develop mental illness unrelated to their criminal conduct. The Court also held that the trial court’s finding that the acquittee’s discharge would be dangerous was supported by clear and convincing evidence, given his history, the violent nature of his offenses, and the short duration of his stable conditional release. The judgment of the Appellate Court was affirmed. View "State v. Foster" on Justia Law

The case involved a defendant who owned a moving business in Connecticut and was accused of murdering a former employee, Reginald, following a dispute during a moving job in Virginia. After a physical altercation between the defendant and Reginald, Reginald returned to Connecticut. Days later, Reginald was shot outside his apartment in Bridgeport. Surveillance footage captured a dark SUV, similar to the defendant’s vehicle, near the scene, and a man exiting the vehicle. A lay witness, May, who had met the defendant only once during the Virginia altercation, later identified the defendant from a still photograph taken from the surveillance footage. Police also recovered a firearm linked to the crime and obtained cell site location information (CSLI) for the defendant’s phone, which placed him near the crime scene and later near the location where the firearm was found.The Superior Court in the judicial district of Fairfield denied in part the defendant’s motion to suppress the CSLI and allowed May’s identification testimony. The jury convicted the defendant of murder and carrying a pistol without a permit. The defendant appealed directly to the Connecticut Supreme Court, arguing that the trial court erred in admitting May’s identification and in denying the motion to suppress the CSLI.The Connecticut Supreme Court affirmed the conviction. It held that the trial court did not abuse its discretion in admitting May’s identification testimony, finding that May’s single but focused encounter with the defendant provided more than minimal familiarity, and that the totality of circumstances—including the quality of the photograph and changes in the defendant’s appearance—supported admissibility. The Court also held that the search warrant affidavit established probable cause for obtaining CSLI for the period immediately surrounding the crime, and any error in the warrant’s broader scope was harmless since only relevant CSLI was introduced at trial. View "State v. Evans" on Justia Law

The case involved the fatal stabbing of a woman in her apartment in Middletown, Connecticut, by her former boyfriend after she ended their relationship. The defendant persistently contacted the victim despite her clear rejections and police warnings. On the night of the murder, the victim was inundated with calls and texts from the defendant, who later left flowers and a note at her door. After the attack, the defendant remained at the scene, called acquaintances, and eventually contacted 911. Physical evidence, including the victim’s blood on the defendant’s clothing and his DNA under her fingernails, linked him to the crime. The defendant gave conflicting accounts to police and left handwritten notes at the scene.The Superior Court for the judicial district of Middlesex denied in part the defendant’s motion to introduce third-party culpability evidence regarding the victim’s neighbor, Adduci, excluding certain videos, messages, prior misconduct, and evidence of Adduci’s mental health decline. The court also denied the defendant’s motion for a mistrial after the prosecutor questioned a detective about whether defense counsel could have requested forensic testing of evidence. The jury found the defendant guilty of murder but not guilty of home invasion, and the court imposed a fifty-seven-year sentence.On direct appeal, the Connecticut Supreme Court assumed, without deciding, that the trial court abused its discretion in excluding the proffered third-party culpability evidence. However, it held that any error was evidentiary, not constitutional, because the excluded evidence was not central to the defense and the defendant was able to present substantial evidence supporting his theory. The Court further found that the exclusion did not substantially affect the verdict given the strength of the state’s case. The Court also held that the trial court did not abuse its discretion in denying the motion for a mistrial, as the prosecutor’s questions did not improperly shift the burden of proof and curative instructions were sufficient. The judgment of conviction was affirmed. View "State v. Myers" on Justia Law

The defendant was convicted of murder and various firearm offenses related to the shooting death of his neighbor. During a police interview, the defendant confessed to the shooting and discussed his struggles with homelessness and issues with his stepmother and the victim. He believed his stepmother and the victim were conspiring against him. At trial, the defendant claimed he acted under extreme emotional disturbance, but the jury rejected this defense.The trial court allowed the defendant's entire police interview into evidence, including parts where he used homophobic slurs, deeming it relevant to his emotional state. The jury found the defendant guilty of murder and other charges, and he was sentenced to forty-five years in prison.On appeal to the Connecticut Supreme Court, the defendant argued that prosecutorial impropriety during closing and rebuttal arguments deprived him of a fair trial. Specifically, he claimed the prosecutors misstated the law on extreme emotional disturbance, denigrated the defense, and invited jury nullification. The court found that the prosecutors did indeed misstate the law by suggesting the defendant's subjective beliefs did not matter and by improperly framing the reasonableness inquiry. These misstatements were central to the case and not cured by the trial court's instructions.The Connecticut Supreme Court concluded that the prosecutorial impropriety deprived the defendant of a fair trial, reversed the murder conviction, and remanded the case for a new trial on that charge. The court also addressed the admissibility of the defendant's use of homophobic slurs, ruling that the trial court did not abuse its discretion in admitting the entire interview, as it was relevant to the defendant's emotional state and the extreme emotional disturbance defense. View "State v. Parris" on Justia Law

The case involved a defendant who, along with an accomplice, planned and executed a robbery of a rideshare driver. The two men lured the victim under the pretense of hiring him for a ride, forced him to drive to a park, robbed him of his belongings, and then both shot him, resulting in the victim’s death. After the crime, the accomplice confided in his girlfriend and a close family friend, describing the events and implicating both himself and the defendant in the robbery and murder.The Superior Court in the judicial district of New Haven presided over the trial. The jury found the defendant guilty of felony murder, murder, robbery in the first degree, and conspiracy to commit robbery in the first degree. The court later vacated the felony murder conviction due to double jeopardy concerns. The court also found the defendant guilty of carrying a pistol without a permit and criminal possession of a firearm after a bench trial. The defendant was sentenced to eighty years of incarceration. Prior to trial, the court denied the defendant’s motion to suppress the accomplice’s statements, finding them admissible under the statement against penal interest exception to the hearsay rule.On appeal, the Supreme Court of Connecticut reviewed whether the trial court erred in admitting the accomplice’s statements to his girlfriend and family friend as evidence. The Supreme Court held that the trial court did not abuse its discretion in admitting these statements. The Court found that the statements were against the accomplice’s penal interest, made voluntarily and soon after the crime to trusted individuals, and were corroborated by other evidence. The Court also determined that any inconsistencies in the statements did not undermine their trustworthiness. The judgment of the trial court was affirmed. View "State v. Traynham" on Justia Law

A 93-year-old woman was found dead in her Stamford, Connecticut home in September 2019, having suffered multiple blunt force injuries. The back door was found open, her wallet was empty and bloodstained, her wedding rings were missing, and a hammer believed to be the murder weapon was found nearby. Video surveillance from a neighboring business showed only one person, later identified as the defendant, entering and exiting the victim’s home during the relevant time. Forensic evidence included the victim’s blood on the defendant’s jeans and the defendant’s DNA on the victim’s fingernails. The defendant initially denied knowing the victim or being in the area, but later admitted to visiting her home that day, claiming it was a brief, uneventful visit.The defendant was charged in the Superior Court for the judicial district of Stamford-Norwalk with murder, home invasion, felony murder, and burglary in the first degree. A jury convicted him on all counts, but the trial court vacated the felony murder conviction on double jeopardy grounds and rendered judgment on the remaining charges, sentencing him to eighty-five years in prison. The defendant appealed, arguing insufficient evidence, improper denial of a third-party culpability jury instruction, and prosecutorial impropriety during closing arguments.The Connecticut Supreme Court affirmed the conviction. It held that the evidence, including surveillance footage, forensic results, and the defendant’s contradictory statements, was sufficient for the jury to find guilt beyond a reasonable doubt. The court found no abuse of discretion in the trial court’s refusal to instruct the jury on third-party culpability, as the presence of unknown male DNA on the hammer did not, in context, provide a credible alternative theory of guilt. The court also concluded that the prosecutor’s remarks during argument were not improper and did not deprive the defendant of a fair trial. View "State v. Simmons" on Justia Law

The defendant was convicted of multiple crimes, including first-degree robbery, following an armed robbery at a restaurant. The police apprehended the defendant shortly after the robbery and conducted a one-on-one showup identification with a restaurant employee, Brinkley, who identified the defendant as one of the perpetrators. The defendant moved to suppress this identification, arguing it was unnecessarily suggestive and unreliable. The trial court denied the motion, finding the identification procedure was not unduly suggestive and, even if it was, the identification was reliable under the totality of the circumstances.The Appellate Court affirmed the trial court's decision, concluding that the showup identification was not unnecessarily suggestive due to the exigent circumstances of the investigation. The court noted that the police needed to quickly determine if they had apprehended the correct suspect to continue their investigation effectively and ensure public safety.The Supreme Court of Connecticut reviewed the case, assuming arguendo that the showup procedure was unnecessarily suggestive. The court focused on the reliability of the identification, considering factors such as Brinkley's opportunity to view the defendant during the crime, her degree of attention, the accuracy of her prior description, her level of certainty during the identification, and the short time between the crime and the identification. The court found substantial evidence supporting the trial court's finding of reliability, noting that Brinkley provided a detailed and accurate description of the perpetrators, identified the defendant without hesitation, and the identification occurred shortly after the crime.The court also addressed the defendant's arguments regarding estimator variables, such as the potential impact of Brinkley's fear, possible marijuana use, and the presence of a weapon. The court concluded that these factors did not undermine the reliability of the identification. Consequently, the Supreme Court of Connecticut affirmed the Appellate Court's judgment, holding that the identification was reliable and did not violate the defendant's due process rights. View "State v. McLaurin" on Justia Law

The defendant was convicted of murder and criminal possession of a firearm in connection with the shooting death of the victim. After the jury foreperson announced a guilty verdict and the jurors collectively confirmed it, defense counsel requested individual polling of the jurors. The first five jurors confirmed the verdict, but the sixth juror, S.C., expressed uncertainty and disagreement. The court stopped polling and excused the jurors to consult with counsel. The court then directed the jurors to resume deliberations, and they later returned a unanimous guilty verdict.In the trial court, the defendant moved for a mistrial, arguing that S.C. would face undue pressure in deliberations. The court denied the motion, noting that S.C. had expressed second thoughts and wanted to continue deliberating. The jury deliberated for an additional two hours after a lunch break and returned a unanimous guilty verdict, which was confirmed by all jurors during a second poll.The Supreme Court of Connecticut reviewed the case and held that the trial court did not abuse its discretion in denying the motion for a mistrial. The court found no impermissible coercion of S.C., noting that the trial court's actions were neutral and allowed the deliberation process to continue without undue pressure. The court also concluded that the trial court's instructions to the jury were adequate and did not require a Chip Smith charge. The court affirmed the judgment of conviction, rejecting the defendant's claims of coercion and procedural error. View "State v. Bolton" on Justia Law