Justia Criminal Law Opinion Summaries

In September 1995, the body of a young woman, later identified as the defendant's daughter, was found in New Britain, Connecticut. The body was wrapped in trash bags and sleeping bags, and the police collected hairs and palm prints from the scene. Around the same time, the defendant told a family member he was leaving the country for a job and that his wife and daughter had already left. In October 1995, the body of the defendant's wife was found in Massachusetts. Both were reported missing later that year. In 2014, law enforcement collected DNA and prints from the defendant, linking him to the crime scene. The defendant was convicted of his wife's murder in Massachusetts and later charged with his daughter's murder in Connecticut.The trial court denied the defendant's motion to dismiss for lack of territorial jurisdiction, applying a presumption that the murder occurred where the body was found. The court also denied the defendant's request for a jury instruction that his palm prints on the trash bags could not establish his connection to the crime unless they were impressed at the time of the crime. The jury found the defendant guilty, and he was sentenced to sixty years in prison.The Connecticut Supreme Court affirmed the trial court's decision. The court held that the presumption that a murder occurred where the body was found was valid and did not violate due process. The court also found sufficient evidence to establish the defendant's identity as the murderer, including consciousness of guilt evidence and physical evidence linking him to the crime scene. The court further held that the trial court properly declined to provide the requested jury instruction on fingerprint evidence, as the palm prints were not the only or principal evidence against the defendant. View "State v. Honsch" on Justia Law

In 1990, the petitioner was convicted of murder, largely based on two cross-racial eyewitness identifications. Both witnesses initially identified another person as the shooter but later identified the petitioner, who was the only Black man at the defense table during a probable cause hearing. The petitioner challenged the identification procedures and jury instructions on appeal, but the Connecticut Supreme Court upheld his conviction.The petitioner filed a habeas petition in 2016, claiming that the admission of unduly suggestive and unreliable eyewitness identification evidence violated his due process rights. He also argued that advances in the science of eyewitness identification since his conviction called into question the validity of his conviction. The habeas court dismissed these claims, concluding they were barred by res judicata and that the decisions in State v. Guilbert and State v. Dickson did not apply retroactively. The court also dismissed and denied other claims of ineffective assistance of counsel.The Connecticut Supreme Court reviewed the case and concluded that the principles set forth in Dickson, which addressed the suggestiveness of first-time, in-court identifications, must apply retroactively on collateral review. The court reasoned that the rule in Dickson was a result of scientific developments that significantly improve the accuracy of convictions and that the petitioner had raised similar claims in his direct appeal. The court reversed the Appellate Court's decision and remanded the case for a trial on the petitioner's due process and actual innocence claims, directing the lower court to apply the holding of Dickson retroactively. View "Tatum v. Commissioner of Correction" on Justia Law

The defendant, Tyhitt Bember, was convicted of felony murder, attempt to commit robbery in the first degree, and carrying a pistol or revolver without a permit in connection with the shooting death of a victim. The defendant, armed with a revolver, had instructed a companion to follow the victim in a car. After confronting the victim on foot, the defendant decided to rob him. When the victim resisted, the defendant shot him five times. The state's case rested almost entirely on the testimony of two witnesses who were facing charges for their involvement in another homicide and had entered into cooperation agreements with the state. The defendant had allegedly confessed his involvement in the victim’s murder to one of these witnesses.The defense moved to preclude the state from introducing the cooperation agreements during its direct examination of the witnesses. The trial court granted the motion but ruled that the prosecutor would be permitted to use leading questions to flesh out the terms of the agreements. The defense also moved for a pretrial hearing regarding the reliability of the witnesses’ proposed trial testimony. Following a hearing, the trial court found that the witnesses’ proposed trial testimony was sufficiently reliable to be admitted at trial.The defendant appealed, arguing that the trial court had abused its discretion in permitting the prosecutor to question the witnesses during direct examination regarding the specific terms of their cooperation agreements with the state. The defendant also claimed that the prosecutor had impermissibly vouched for the witnesses’ credibility by introducing the truthfulness provisions of their cooperation agreements, eliciting testimony from the witnesses that their attorneys were present in the courtroom, and referencing their prior testimony in other criminal cases on behalf of the state. The defendant further claimed that the trial court had abused its discretion in concluding that the witnesses’ testimony was reliable and admissible.The Supreme Court of Connecticut affirmed the trial court's decision. The court held that the defendant had waived his claim regarding the prosecutor's questioning of the witnesses about their cooperation agreements. The court also held that the prosecutor's introduction of the truthfulness provisions of the witnesses' cooperation agreements did not constitute improper vouching. The court further held that the trial court did not abuse its discretion in determining that the witnesses' proposed trial testimony was sufficiently reliable to be admissible at trial. View "State v. Bember" on Justia Law

A man convicted of sexual assault and risk of injury to a child appealed his conviction, arguing that he was entitled to access the content of handwritten journals authored by the complainant. The complainant had revealed the existence of these journals during the trial, stating that they were created as part of her therapy following the abuse and contained details about her relationship with the defendant and the abuse he had inflicted. The defendant claimed that these journals constituted a "statement" under relevant rules of practice and that his rights were violated as the prosecutors did not personally review the journals for exculpatory information.The Appellate Court affirmed the conviction, concluding that the defendant had waived his claim to the journals and that the prosecutors were not constitutionally required to personally review the journals. The defendant appealed to the Supreme Court of Connecticut, which agreed with the state's alternative argument that the journals were not subject to disclosure because they did not constitute a statement that was adopted or approved by the complainant. The court also concluded that the Brady review of the journals by a nonlawyer member of the state’s attorney’s office was constitutionally adequate. Therefore, the court affirmed the judgment of the Appellate Court. View "State v. C." on Justia Law

The case revolves around a plaintiff who was arrested for operating a motor vehicle while under the influence of intoxicating liquor. The arresting officer prepared a report of the incident and mailed it to the Department of Motor Vehicles (DMV), but not within the three business days required by statute. At the plaintiff's license suspension hearing, the plaintiff's attorney objected to the admission of the report on the grounds that it was not prepared and mailed within the statutory timeframe. The hearing officer overruled the objection and admitted the report, which was the only evidence submitted at the hearing.The trial court dismissed the plaintiff's appeal, concluding that strict adherence to the preparation and mailing requirement was not necessary for the report to be admissible. The Appellate Court affirmed the trial court's judgment, concluding that the preparation and mailing requirement is directory, and therefore, strict compliance with that requirement is not necessary for a report to be admissible at a license suspension hearing.The Supreme Court of Connecticut reversed the Appellate Court's judgment. The court held that the hearing officer abused her discretion in admitting an incident report that did not strictly comply with the preparation and mailing provision of the statute in the absence of testimony from the arresting officer. The court concluded that the preparation and mailing requirement was mandatory because it promoted the accuracy and reliability of the information that would be used at a license suspension hearing. The court clarified that the statute describes substantive requirements that incident reports must meet, and the failure to meet those requirements renders a report inadmissible insofar as it fails to satisfy the exception for the report to be admitted without the need to produce the arresting officer at the suspension hearing. View "Marshall v. Commissioner of Motor Vehicles" on Justia Law

The defendant, Gonzalo Diaz, was convicted of felony murder, burglary in the first degree, conspiracy to commit burglary in the first degree, attempt to commit robbery in the first degree, and criminal possession of a firearm in connection with a shooting death. The defendant appealed, claiming that the trial court committed plain error by instructing the jury that it could consider his interest in the outcome of the trial when assessing his credibility. He also claimed that the prosecutor made improper remarks during his cross-examination and during rebuttal argument.The Superior Court in the judicial district of Waterbury found Diaz guilty of felony murder, manslaughter in the first degree with a firearm, burglary in the first degree, conspiracy to commit burglary in the first degree, and attempt to commit robbery in the first degree. The court also found him guilty of criminal possession of a firearm. The court later vacated the conviction for manslaughter in the first degree with a firearm.The Connecticut Supreme Court affirmed the lower court's decision. The court agreed that the trial court's instruction to the jury was erroneous, but it did not result in manifest injustice. The court also found that the prosecutor's remarks were not improper. The court concluded that the defendant failed to establish that the evidence adduced at trial, the disputed factual issues before the jury, and the instructions as a whole gave rise to the danger of juror misunderstanding or confusion. Therefore, the court affirmed the judgment of the trial court. View "State v. Diaz" on Justia Law

The defendant, Dwayne Sayles, was convicted of felony murder and conspiracy to commit robbery in the first degree, among other crimes, in connection with his role in the robbery of a convenience store and the shooting death of the store clerk. On appeal, Sayles challenged the trial court's denial of his motions to suppress evidence of his cell phone and the data contained therein. He argued that the police had violated his rights under Miranda and the Connecticut constitution when they continued to interrogate him after he had invoked his right to counsel, and that the seizure of his cell phone violated the fourth amendment to the U.S. constitution and the Connecticut constitution.However, the Supreme Court of Connecticut concluded that any error in the admission of the contents of Sayles' cell phone was harmless beyond a reasonable doubt due to the overwhelming wealth of evidence against him. This evidence included surveillance footage from inside of the convenience store, detailed testimony from a co-conspirator about Sayles' and his own involvement in the events, testimony from a jailhouse informant that Sayles had confessed to his involvement in the crimes, and a corroborating statement made to the police by a friend of Sayles. The court also noted significant evidence of Sayles' consciousness of guilt, such as testimony that he had directed his cousin to assault a potential witness to force him to recant his testimony. Physical evidence, including a ski mask and gloves found during the search of Sayles' residence and cell phone location data, further corroborated the testimony and statements. Given this, the court affirmed the Appellate Court’s judgment and declined to address Sayles' constitutional challenges. View "State v. Sayles" on Justia Law

In this case, the defendant, Lawrence Lee Henderson, was convicted of home invasion after a jury trial. During the trial, the defendant contracted COVID-19, resulting in a 25-day delay in jury deliberations. When the deliberations resumed, the jury found the defendant guilty of home invasion but not guilty of other charges and lesser included offenses.The defendant appealed, claiming that the court should reverse his conviction of home invasion or grant him a new trial on that charge because the jury’s verdicts of guilty of home invasion and not guilty of a lesser included offense were legally inconsistent. He also claimed that the trial court abused its discretion by failing to declare a mistrial when he contracted COVID-19, which resulted in the delay in jury deliberations.The court upheld the trial court’s decision, holding that legally inconsistent verdicts are unreviewable on appeal, following its precedent in State v. Arroyo, which was consistent with United States Supreme Court precedent and that of the majority of other jurisdictions. In terms of the COVID-19 delay, the court found that the trial court did not abuse its discretion in denying the defendant's motion for a mistrial, as the delay was unavoidable due to the pandemic, and the defendant failed to demonstrate actual prejudice from the delay. View "State v. Henderson" on Justia Law

The case involves a defendant who was convicted, after a jury trial, of burglary in the first degree, criminal mischief in the first degree, and threatening in the second degree, among other crimes. The defendant had unlawfully entered his brother's residence and caused significant damage within it. Upon appeal, the defendant argued that the trial court had committed plain error by not identifying the specific crime or crimes he allegedly intended to commit when he entered the residence during the jury instruction on first-degree burglary.However, the Supreme Court of Connecticut held that the Appellate Court correctly concluded that the trial court had not committed plain error. The trial court's instruction accurately recited the elements of the burglary charge and clarified that the intent to commit a crime within the building is a distinct element. Furthermore, the court noted that although it is the better practice for trial courts to name the crime or crimes and define such elements in its instructions, it has never been clearly held to be mandatory.Additionally, the court found that even if there was a patent error in the court’s instruction, the omission did not result in a manifest injustice. The evidence presented at trial established that the defendant had violently forced his way into the residence and caused extensive damage, which satisfied the intent element. View "State v. Kyle A." on Justia Law

In the State of Connecticut, the petitioner, who was convicted of felony murder and other crimes, filed a petition for a writ of habeas corpus in 2018, more than five years after his conviction was deemed final. The petitioner initially filed a timely habeas petition in 2012 but withdrew it due to dissatisfaction with his assigned counsel. When filing his 2018 habeas petition, the Commissioner of Correction moved for an order to show cause why the petition should not be dismissed as untimely under § 52-470 (c) and (e). The petitioner argued that good cause existed to excuse the untimely filing since his previous counsel had failed to inform him of the deadline to refile his petition. The habeas court dismissed the 2018 petition as untimely, a decision upheld by the Appellate Court.On appeal to the Supreme Court of Connecticut, the Court reversed the judgment of the Appellate Court, concluding that the habeas court’s determination that no good cause existed was based on a clearly erroneous factual finding. The Court found that the habeas court wrongly assumed that the petitioner's previous counsel had advised him to refile his habeas petition immediately after withdrawing the first one. The Court also clarified that, under the totality of the circumstances, ineffective assistance of counsel can be considered an external, objective factor that could establish good cause to excuse the late filing of a habeas petition under § 52-470 (c) and (e). The case was remanded for a new hearing and a good cause determination under § 52-470 (c) and (e) in light of its factual findings with respect to the performance of prior habeas counsel. View "Rose v. Commissioner of Correction" on Justia Law