Justia Criminal Law Opinion Summaries

After a jury trial, Defendant was convicted of murder. Defendant appealed, arguing that the trial court violated his right to present a defense by limiting his cross-examination of investigating police officers as to whether the murder investigation conformed to general police practices and/or standard police investigative procedures. The Appellate Court agreed with Defendant and reversed and remanded the case for a new trial. The Supreme Court reversed, holding that there was an absence of a sufficient offer of proof to such a line of inquiry, and therefore, the trial court did not improperly preclude Defendant’s inadequate investigation defense strategy. View "State v. Wright" on Justia Law

In 1992, Defendant was convicted of murder. In 2010, Defendant filed a third motion to correct an illegal sentence. The trial court denied the motion on the merits. Defendant appealed, arguing that the trial court violated his right to counsel by denying his request for the assistance of counsel without adhering to the procedure set forth in Anders v. California. The Appellate Court reversed the trial court’s denial of Defendant’s request for the appointment of counsel, holding that Anders applied to Defendant’s claim and that the requirements of Anders were not satisfied in this case. The Supreme Court affirmed, holding (1) the Anders procedure is not required to safeguard the statutory right to counsel in the context of a motion to correct an illegal sentence; but (2) the trial court erred by failing to appoint counsel to assist Defendant in determining whether a sound basis existed for him to file his motion, and the error was not harmless. View "State v. Francis" on Justia Law

Plaintiff was a registered sex offender when he was admitted to the state rental assistance program. Thereafter, the legislature promulgated section 17b-812-13(9) of the Regulations of Connecticut States Agencies, which makes sex offender registration a ground for termination or denial of rental program assistance. The Commissioner of Housing (Commissioner) subsequently terminated Plaintiff’s rental program benefits. Plaintiff took an administrative appeal of the Commissioner’s decision to the trial court, which concluded that the Commissioner’s application of section 17b-812-13(9) was not retroactive and therefore did not exceed the authority granted to the Commissioner by the legislature. The Supreme Court reversed, holding (1) the Commissioner applied section 17b-812-13(9) of the regulations retroactively in this case by imposing a new obligation on Plaintiff’s sex offender status that terminated his rental program assistance; and (2) such retroactive application of the regulation was not statutorily authorized, and therefore, the trial court erred in dismissing Plaintiff’s administrative appeal. View "Shannon v. Comm’r of Housing" on Justia Law

After a jury trial, Petitioner was convicted of capital felony and other crimes. Petitioner was sentenced to death. Petitioner later filed a petition for a writ of habeas corpus, raising several challenges to his death sentence. The habeas court denied the petition. After Petitioner filed his appeal, the Supreme Court granted Petitioner permission to file a supplemental brief on the question of whether the legislature’s enactment of P.A. 12-5 rendered the death penalty, as applied to him and other similarly situated defendants, unconstitutional. While the appeal was pending, the Supreme Court decided State v. Santiago, which held that the imposition of the death penalty on defendants sentenced to death for capital crimes committed before the effective date of the legislation was unconstitutional under the state constitution. The Supreme Court reversed the denial of Petitioner’s habeas petition, holding that the death penalty was unconstitutional as applied to Petitioner. View "Webb v. Commissioner of Correction" on Justia Law

After a jury trial, Defendant was convicted of sexual assault in the first degree and sexual assault in the third degree. The Supreme Court affirmed, holding (1) the trial court properly denied Defendant’s motion to suppress statements he made to the police; (2) the trial court properly admitted evidence of uncharged sexual misconduct pursuant to State v. DeJesus; and (3) the trial court’s application of the Supreme Court’s decision in DeJesus and the relevant revision of section 4-5(b) of the Connecticut Code of Evidence did not violate Defendant’s equal protection rights under the federal and state constitutions. View "State v. Arias" on Justia Law

After a jury trial, Defendant, the former mayor of the city of Hartford, was convicted of bribe receiving, fabricating evidence, and larceny by extortion. The State had charged Defendant with the offenses in two separate informations. Before trial, however, the trial court granted the State’s motion to consolidate the charges, and the cases were tried together for purposes of judicial economy. Defendant filed two motions to sever, arguing that consolidation improperly compromised his right to choose whether to testify on his own behalf in one case but to remain silent in the other case. The trial court denied the motions. The Appellate Court reversed and remanded the cases to be retried in two separate proceedings, concluding that the trial court’s refusal to sever the cases had compromised Defendant’s ability to testify in one case, causing him substantial prejudice. The Supreme Court affirmed, holding that the trial court abused its discretion in declining to sever the cases because Defendant made a timely and compelling showing that he had important testimony to give in one case and a strong need to refrain from testifying in the other. View "State v. Perez" on Justia Law

Defendant entered conditional pleas of nolo contendere to one count each of manufacturing a bomb and possession of child pornography in the first degree. Defendant appealed the trial court’s denial of his motion to suppress evidence discovered after the execution of an administrative search warrant at his apartment, arguing that the trial court erred in denying his motion because the administrative search warrant was invalid and improperly executed. The Supreme Court affirmed, holding that the administrative search warrant was valid because (1) the superior court judge who issued the administrative search warrant had the authority to issue the warrant; (2) the warrant was supported by the requisite probable cause; and (3) there was no error in the issuance of the warrant during an ex parte proceeding. Further, the search was lawful because excessive force was not used during its execution. View "State v. Saturno" on Justia Law

Conn. Gen. Stat. 54-102 authorizes the Commissioner of Correction to collect DNA samples from incarcerated felons in order to maintain a DNA data bank to assist in criminal investigations. In 2005, Defendant pleaded guilty to murder. In 2009, the Department of Correction directed Defendant to submit to the taking of a DNA sample pursuant to Conn. Gen. Stat. 54-102g, but Defendant refused to comply. The State filed a motion for permission to use reasonable physical force to collect the DNA sample from Defendant. The trial court granted the motion. Defendant was subsequently convicted of refusing to submit to the taking of a sample for DNA analysis in violation of section 54-102g(g). The Appellate Court upheld both Defendant’s conviction and the grant of the State’s motion for permission to use reasonable physical force to obtain the sample, concluding (1) section 54-102g is regulatory, rather than punitive, in nature, and therefore, the trial court had jurisdiction to consider the State’s motion; and (2) application of the statute to Defendant did not violate his constitutional guarantee of due process or the prohibition against double jeopardy. The Supreme Court affirmed, holding that the Appellate Court properly resolved both of Defendant’s claims. View "State v. Drakes" on Justia Law

Conn. Gen. Stat. 54-102 authorizes the Commissioner of Correction to collect DNA samples from incarcerated felons in order to maintain a DNA data bank to assist in criminal investigations. In 1997, Defendant was convicted of robbery and other offenses. More than a decade later, the Department of Correction instructed Defendant to submit to the taking of a DNA sample pursuant to Conn. Gen. Stat. 54-102g, but Defendant refused to comply. The State filed a motion for permission to use reasonable physical force to collect the DNA sample from Defendant. The trial court granted the motion. Defendant was subsequently convicted with refusing to submit to the taking of a sample for DNA analysis in violation of section 54-102g(g). The Appellate Court upheld both Defendant’s conviction and the grant of the State’s motion for permission to use reasonable physical force to obtain the sample, concluding (1) section 54-102g is regulatory, rather than punitive, in nature, and therefore, the trial court had jurisdiction to consider the State’s motion; and (2) application of the statute to Defendant did not violate his due process rights or contravene the ex post facto clause. The Supreme Court affirmed, holding that the Appellate Court properly resolved both of Defendant’s claims. View "State v. Banks" on Justia Law

After a joint jury trial with his codefendant, Petitioner was convicted of ten charges arising from a murder and robbery. The Appellate Court affirmed. Petitioner thereafter filed a petition for a writ of habeas corpus, claiming that his trial counsel provided ineffective assistance by failing to conduct an adequate pretrial investigation and failing adequately to present a defense at trial. The habeas court granted the petition and ordered that Petitioner’s conviction be set aside, concluding that counsel’s failure to obtain information regarding a stolen cell phone before trial was deficient performance and that the deficient performance prejudiced Petitioner’s defense. The Supreme Court reversed, holding that counsel’s failure to investigate the issue of the stolen cell phone evidence was not prejudicial under Stickland v. Washington. View "Horn v. Comm’r of Corr." on Justia Law