Justia Criminal Law Opinion Summaries

The Supreme Court affirmed the judgment of the appellate court affirming the trial court's judgment of conviction of murder, holding that the appellate court correctly concluded that any error relating to the admission of testimony from a witness called during the state's case on rebuttal was harmless.On appeal, Defendant argued that the testimony of Mark Manganello, the witness at issue, fatally undermined her theory of self defense and that the testimony likely had a substantial effect on the jury's verdict. The Supreme Court disagreed, holding that the appellate court properly concluded that any evidentiary error committed by the trial court with respect to the admission of Manganello's testimony was necessarily harmless. View "State v. Carey" on Justia Law

The Supreme Court reversed the judgment of the appellate court affirming Defendant's conviction of six counts of sexual assault and four counts of risk of injury to a child from the sexual abuse of his girlfriend's daughter, J, holding that the trial court erred in excluding screenshot photographs of text messages purportedly sent by J to Defendant's niece.Specifically, the Supreme Court held (1) the appellate court correctly upheld the admission into evidence of a video recording of a forensic interview of J by a nonmedical professional under the medical diagnosis and treatment exception to the hearsay rule; but (2) the appellate court incorrectly concluded that the trial court had properly excluded J's text messages on the ground that they had not been sufficiently authenticated, and the improper exclusion of the text messages requires reversal of the judgment and a new trial. View "State v. Manuel T." on Justia Law

The Supreme Court reversed the judgment of conviction rendered by the trial court following Defendant's conditional plea of nolo contendere to the charge of possession of a controlled substance with intent to sell, holding that the trial court erred in denying Defendant's motion to suppress.On appeal, Defendant argued that she was illegally detained, along with her codefendant, in a car in the parking lot of a multiunit apartment building because the police lacked either a warrant or a reasonable, articulable suspicion of criminal activity. The Supreme Court reversed, holding that Defendant's detention was not permissible under the exception to the Fourth Amendment's warrant requirement articulated in Michigan v. Summers, 452 U.S. 692, and Bailey v. United States, 568 U.S. 186 (2013) because Defendant was not within the "immediate vicinity" of the apartment to be searched. View "State v. Espino" on Justia Law

The Supreme Court reversed the judgment of conviction rendered by the trial court following Defendant's conditional plea of nolo contendere to the charge of possession of a controlled substance with intent to sell, holding that the trial court erred in denying Defendant's motion to suppress.Defendant sought to suppress evidence seized after his warrantless detention in the parking lot of a multiunit apartment building. The trial court denied the suppression motion. The Supreme Court reversed, holding that Defendant was not an "occupant" within the "immediate vicinity" of the premises subject to a search warrant under the exception to the Fourth Amendment's warrant requirement set forth in Michigan v. Summers, 452 U.S. 692 (1981), and Bailey v. United States, 568 U.S. 186 (2013). View "State v. Rolon" on Justia Law

The Supreme Court affirmed the decision of the Appellate Court affirming the judgments of the trial court convicting Defendant of, among other charges, aggravated sexual assault in the first degree and risk of injury to a child, holding that the trial court properly found that Defendant's waiver of his right to a jury trial was constitutionally valid.Following a seven day trial to the court, Defendant was found guilty of multiple offenses. On appeal, Defendant challenged the finding of the trial court that his jury trial waiver was knowing, intelligent, and voluntary. The Appellate Court affirmed. Defendant appealed, arguing that the trial court should have recognized that he was unready and incapable of waiving a jury trial. The Supreme Court affirmed, holding that the Appellate Court's opinion fully addressed Defendant's arguments, and there was no need to repeat that discussion. View "State v. Kerlyn T." on Justia Law

The Supreme Court affirmed Defendant's conviction of murder, two counts of attempted murder and related crimes, holding that the trial court did not abuse its discretion in admitting into evidence four photographs that depicted the bloody interior of a vehicle used to transport two victims shot by Defendant to the hospital.At Defendant's second jury trial on murder, attempted murder, and first degree assault charges, the State admitted into evidence four photographs of the bloody interior of the car that one victim used to drive herself and other victim to the hospital. On appeal, Defendant argued that the four photographs were unduly prejudicial because of their inflammatory nature and that the evidentiary error was harmful. The Supreme Court affirmed, holding that the trial court's determination that the photographs were more probative than prejudicial was not an abuse of discretion. View "State v. Best" on Justia Law

The Supreme Court reversed the judgment of the habeas court denying Petitioner's petition for certification to appeal from the dismissal of his petition for a writ of habeas corpus, holding that the habeas court should have declined to issue the writ pursuant to Practice Book 23-24 rather than dismissing the case pursuant to Practice Book 23-29.Acting sua sponte and without providing Petitioner with notice or a hearing, the habeas court dismissed Petitioner's habeas petition pursuant to section 23-29 for lack of jurisdiction on the grounds that Petitioner was not in custody for the conviction being challenged. The Supreme Court reversed, holding (1) the habeas court correctly determined that it lacked subject matter jurisdiction because Petitioner was not in custody for the challenged conviction; but (2) the dismissal of the petition pursuant to Practice Book 23-29 was error. View "Cookish v. Commissioner of Correction" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of two counts of sexual assault in the first degree and one count of criminal attempt to commit sexual assault in the first degree, holding that there was no error.Specifically, the Supreme Court held (1) the trial court did not violate Defendant's right to confrontation by allowing testimony about the results of a DNA identification analysis without requiring testimony from the individual who generated the DNA profiles; (2) Defendant's claim that his due process rights were violated by the introduction of DNA identification evidence that was allegedly unreliable failed under the third prong of State v. Golding, 567 A.2d 823 (Conn. 1989); and (3) there was sufficient evidence to establish Defendant's guilt beyond a reasonable doubt. View "State v. Rodriguez" on Justia Law

The Supreme Court affirmed the judgment of the Appellate Court affirming Defendant's conviction, holding that Defendant's conviction of two counts of violating a standing criminal protective order did not violate Defendant's right against double jeopardy and that any possible instructional error in the trial court's definition of "harassing" was harmless.Defendant was convicted of two counts of criminal violation of a standing protective order, one count of threatening in the second degree, and one count of threatening in the second degree. The convictions arose from a series of statements Defendant made to the person protected by the order during a court hearing. The Supreme Court affirmed, holding (1) Defendant's two convictions for violation of a standing criminal protective order did not violate the constitutional protection against double jeopardy; and (2) even if this Court were to assume that Defendant's allegations of instructional error were valid, any impropriety was harmless. View "State v. Cody M." on Justia Law

The Supreme Court affirmed the judgment of the Appellate Court affirming Defendant's judgment of conviction for criminal trespass in the first degree, holding that that the Appellate Court correctly concluded that the prerequisites set forth in State v. Whistnant, 427 A.2d 414 (1980), for obtaining a jury instruction on a lesser included offense were not satisfied in this case.On appeal, Defendant argued that the trial court should have instructed the jury on the infraction of simple trespass as a lesser included offense. The Appellate Court disagreed, concluding that the requested instruction failed the third and fourth elements of Whistnant. The Supreme Court agreed, holding that the Appellate Court did not err in concluding that the trial court properly declined to instruct the jury on the infraction of simple trespass. View "State v. Marsala" on Justia Law