Justia Criminal Law Opinion Summaries

The Supreme Court reversed the judgment of the appellate court affirming the judgment of the trial court denying Defendant's motion to correct an illegal sentence, holding that the trial court lacked subject matter jurisdiction to entertain Defendant's motion because the motion sought only to modify Defendant's conviction, not his sentence.Defendant was convicted of felony murder and manslaughter. The trial court merged the conviction for manslaughter with the felony murder conviction for sentencing purposes. In his motion to correct an illegal sentence, Defendant argued that his sentence was illegal under the supervisory rule set forth in State v. Polanco, 61 A.3d 1084 (2013). The trial court concluded that Polanco did not apply retroactively and denied the motion. The appellate court affirmed. The Supreme Court reversed, holding that the trial court lacked jurisdiction to entertain Defendant's motion to correct an illegal sentence. View "State v. Smith" on Justia Law

The Supreme Court reversed the judgment of the appellate court affirming Defendant's conviction of assault in the second degree, holding that the appellate court erred in determining that a challenged jury instruction did not mislead the jury or otherwise deprive Defendant of his right to present an investigative inadequacy defense.At trial, Defendant's main defense was that the police had conducted an inadequate investigation of the incident leading to his conviction. On appeal, Defendant claimed that the jury instructions deprived him of his right to present his defense. The appellate court affirmed, holding that the trial court's jury instruction on investigative inadequacy was consistent with investigative inadequacy instructions approved by the Supreme Court. The Supreme Court reversed, holding that the model jury instruction utilized by the court in this case may have misled the jury or otherwise deprived Defendant of his right to present an investigative inadequacy defense. View "State v. Gomes" on Justia Law

The Supreme Court held that the legislature's action in amending Conn. Gen. Stat. 21a-279(a) to reclassify a first offense for possession of narcotics from a class D felony subject to a maximum sentence of imprisonment of seven years to a class A misdemeanor subject to a maximum sentence of one year of incarceration did not apply retroactively to criminal cases pending at the time the amendment became effective.Defendant was arrested and charged with violating section 21a-279(a) prior to the enactment of Spec. Public Acts, Sess. June 2015, No. 15-2, 1, which amended the statute. Defendant was convicted and sentenced after the amendment's enactment. On appeal, Defendant argued that the lower courts erred in determining that Spec. Sess. P.A. 15-2, 1 does not apply retroactively, and therefore, the sentence imposed on him was illegal. The Supreme Court affirmed, holding (1) the plain language of Spec. Sess. P.A. 15-2, 1 clearly and unambiguously prohibits retroactive application; and (2) this Court declines to adopt the amelioration doctrine. View "State v. Bischoff" on Justia Law

The Supreme Court affirmed the judgment of the appellate court denying habeas corpus relief after concluding that the doctrine of collateral estoppel barred Petitioner from litigating the issue of whether he was prejudiced he was prejudiced by his counsel's failure to object to the prosecutor's improper comments during closing argument at his criminal trial, holding that Petitioner failed to demonstrate prejudice.Petitioner, who was convicted of murder, filed a petition for a writ of habeas corpus alleging that his criminal trial counsel rendered ineffective assistance by, among other things, failing to object to the prosecutor's improper remarks during closing argument. The court denied the petition, concluding that Petitioner had failed to demonstrate that he had suffered prejudice. The appellate court affirmed on the grounds that Petitioner was collaterally estopped from litigating the issue of prejudice. The Supreme Court affirmed, holding (1) the doctrine of collateral estoppel did not apply; and (2) Petitioner failed to demonstrate prejudice from his counsel's performance. View "Ross v. Commissioner of Correction" on Justia Law

The Supreme Court affirmed the judgment of the trial court revoking Defendant's probation and sentencing him to a two-year term of imprisonment, holding that the trial court did not improperly deny Defendant's motion to dismiss the violation of probation charge.On appeal, Defendant argued that the condition of probation upon which the violation of probation charged was predicated violated his Fourteenth Amendment rights to due process and equal protection as well as the Eighth Amendment prohibition against the imposition of cruel and unusual punishment. The Supreme Court affirmed, holding that Defendant's claims on appeal failed. View "State v. Imperiale" on Justia Law

The Supreme Court affirmed Defendant's conviction of the sexual assault of a twelve-year-old girl and his sentence of thirty-three years, holding that the trial court's enhancement of Defendant's sentence was not fundamentally unfair.On appeal, Defendant argued that, at sentencing, the trial court violated his due process right by penalizing him for refusing to apologize for his criminal misconduct. Specifically, Defendant argued that his sentence contravened his constitutional right against self-incrimination because an apology would necessarily have required him to admit guilt. The Appellate Court affirmed, concluding that there was no evidentiary support for Defendant's contention that the trial court had increased his sentence because of his unwillingness to apologize to the victims. The Supreme Court affirmed, holding that the Appellate Court properly concluded that the trial court did not penalize Defendant for maintaining his innocence at sentencing. View "State v. Angel M." on Justia Law

The Supreme Court reversed the judgment of the appellate court, which reversed the judgment of the trial court convicting Defendant of burglary in the third degree and other offenses in connection with a break-in, holding that the appellate court improperly addressed an issue of evidentiary sufficiency sua sponte without calling for supplemental briefing, as required by Blumberg Associates Worldwide, Inc. v. Brown & Brown of Connecticut, Inc., 84 A.3d 840 (Conn. 2014).On appeal, the appellate court reversed Defendant's conviction for tampering with physical evidence, concluding that there was insufficient evidence for the jury to have reasonably concluded that Defendant intended to tamper with the evidence at issue. In reaching its decision, the appellate court recognized that the issue was distinct from Defendant's sufficiency argument on appeal. The Supreme Court reversed, holding that the appellate court violated the mandate in Blumberg by raising a different claim of evidentiary sufficiency sua sponte, without calling for supplemental briefing from the parties. View "State v. Stephenson" on Justia Law

The Supreme Court affirmed the judgment of the appellate court affirming the judgment of the trial court revoking Defendant's probation following an incident in which he allegedly robbed and threatened a customer, Lawrence Welch, at a Dunkin' Donuts store, holding that Welch's identification of Defendant was reliable notwithstanding the inherent suggestiveness of the showup procedure.After Defendant was charged with violating a condition of his probation he filed a motion to suppress Welch's identification of him, claiming that the showup procedure violated his due process rights. The trial court denied the motion and found that Defendant had violated his probation. The appellate court affirmed, concluding that the identification procedure was not unnecessarily suggestive due to the exigencies of the ongoing investigation. The Supreme Court affirmed, holding that, considering the totality of the circumstances, Welch's identification of Defendant was reliable. View "State v. Ruiz" on Justia Law

The Supreme Court reversed the judgment of the appellate court affirming Defendant's conviction of murder, holding that the appellate court improperly upheld the trial court's denial of Defendant's motion for a Porter hearing on the reliability of ballistics evidence based solely on the holding in State v. Legnani, 951 A.2d 674 (Conn. 2008).On appeal, Defendant argued that reports issued by the National Academy of Sciences called into question the reliability of methodologies employed in firearm and toolmark examinations and that a Porter hearing was necessary to determine if such evidence was admissible. The trial court construed Legnani by concluding that a Porter hearing on the reliability of firearm and toolmark examinations was not necessary. The Supreme Court reversed, holding that the trial court erred in denying Defendant's motion for a Porter hearing based solely on Legnani without considering new evidence offered by Defendant, and the error was not harmless. View "State v. Raynor" on Justia Law

The Supreme Court reversed the judgment of the appellate court holding that the special credibility instruction required in State v. Patterson, 886 A.2d 777 (Conn. 2005), did not apply to an incarcerated informant who offered his testimony that the defendant confessed to him when they socialized outside of prison in exchange for favorable treatment of the informant by the state, holding that the trial court improperly denied Defendant's unopposed request for a jailhouse informant instruction.Defendant was convicted of murder, carrying a pistol without a permit, and criminal possession of a firearm. At the conclusion of trial, defense counsel requested a special credibility instruction with respect to the testimony of a witness in accordance with Patterson, arguing that a jailhouse informant instruction was warranted. The state did not object to the requested instruction, but the trial court declined to issue it and instead issued a general credibility instruction. The appellate court affirmed. The Supreme Court reversed, holding that, under the facts of this case, the trial court improperly denied Defendant's unopposed request for a jailhouse informant instruction. View "State v. Jones" on Justia Law