Justia Criminal Law Opinion Summaries

Defendant was convicted of possession of narcotics with intent to sell and conspiracy to possess narcotics with intent to sell. The Appellate Court reversed and ordered a new trial, concluding that the prosecutor violated a court order concerning the permissible boundaries of argument and referred to facts outside the record, thus rendering the trial fundamentally unfair. The State appealed, claiming that the prosecutor’s remarks were not improper. The Supreme Court reversed, holding that one of the prosecutor’s arguments was improper, but this improper argument did not deprive Defendant of his due process right to a fair trial because there was no reasonable likelihood that the prosecutor’s comments affected the jury’s verdict. View "State v. Martinez" on Justia Law

After a jury trial, Defendant was found guilty of conspiracy to commit assault in the first degree. Defendant appealed, claiming that his exclusion from an in chambers discussion regarding defense counsel’s possible conflict of interest violated his constitutional right to be present at all critical stages of the prosecution. The claim was unpreserved and so Defendant sought review pursuant to State v. Golding. The Appellate Court affirmed the judgment of conviction, determining that the record was inadequate to review the claim. The Supreme Court affirmed, holding that the record, as it presently stood, was not adequate for appellate review. View "State v. Walker" on Justia Law

After a jury trial, Defendant was convicted of two counts of aggravated sexual assault of a minor, in violation of Conn. Gen. Stat. 53a-70c(a)(1) and (6), and other offenses. Defendant sought review pursuant to State v. Golding, claiming that his convictions and sentences for two counts of aggravated sexual assault of a minor violate his right to be free of double jeopardy because they constitute multiple punishments for the same offense. The Supreme Court affirmed, holding that because subdivisions (1) and (6) of section 53a-70c(a) each require proof of a fact that the other does not, and because nothing in either the statutory text or legislative history of the statute reveals a contrary legislative intent, multiple convictions under section 53a-70c for the same transaction do not run afoul of the double jeopardy clause. View "State v. Wright" on Justia Law

Petitioner was convicted of sexual assault in the first degree and risk of injury to a child for sexually abusing a four-year-old girl. Petitioner subsequently filed a petition for a writ of habeas corpus, alleging that his counsel provided ineffective assistance by failing to present expert testimony regarding the suggestibility of young children and the reliability of a child’s recollection of sexual abuse. The habeas court reversed, concluding that Petitioner established that his trial counsel had rendered ineffective assistance. The Appellate Court affirmed. The Supreme Court reversed, holding that the failure of Petitioner’s trial counsel to present the expert testimony was objectively reasonable because there was a legitimate, strategic reason for not presenting such testimony. View "Michael T. v. Comm’r of Corr." on Justia Law

Pursuant to a plea agreement, Petitioner pleaded guilty to manslaughter in the first degree with a firearm. The plea agreement stated that Petitioner would receive a total sentence of between twenty and twenty-five years’ imprisonment and that defense counsel had a right to argue for a sentence beneath the twenty-five year cap. At sentencing, defense counsel agreed with the prosecutor’s recommendation that the trial court should impose the maximum sentence under the agreement. The trial court sentenced Petitioner to twenty-five years imprisonment. Petitioner subsequently filed a petition for a writ of habeas corpus, claiming ineffective assistance of counsel. The habeas court denied relief, determining that Petitioner failed to prove ineffective assistance of counsel under Strickland v. Washington. The Appellate Court affirmed, concluding that the habeas court properly determined that Petitioner failed to prove actual prejudice under Strickland. The Supreme Court reversed in part, holding that the habeas court improperly applied Strickland to Petitioner’s ineffective assistance claim because a complete breakdown in the adversarial process occurred, and therefore, Petitioner’s claim was instead controlled by United States v. Cronic, under which prejudice should be presumed. View "Davis v. Comm’r of Corr." on Justia Law

After a jury trial, Defendant was found guilty of larceny in the third degree. The State sought to have Defendant’s sentence enhanced under Conn. Gen. Stat. 53a-40b because Defendant had committed the larceny while he was released on bond. Prior to the hearing on the sentence enhancement, the records for Defendant’s previous arrests had been erased in accordance with Conn. Gen. Stat. 54-142a. The trial court allowed the State to introduce those records into evidence and, relying solely on those records, found that Defendant had committed the larceny while he was on release. The Appellate Court reversed, concluding that the trial court had improperly allowed the State to introduce the erased records and that the State could not seek to prove the basis for the sentence enhancement at a new hearing. The Supreme Court reversed in part, holding (1) the trial court improperly permitted the State to introduce the erased records to prove the basis for the sentence enhancement under section 53a-40b; but (2) on remand, the State is not foreclosed from seeking to establish the basis for Defendant’s sentence enhancement by use of evidence other than the erased records. View "State v. Apt" on Justia Law

Defendant was found not guilty of certain offenses by reason of mental disease or defect and transferred to a maximum security psychiatric facility. Defendant was charged with new, violent crimes while housed at the facility. The trial court set a monetary bond as a condition of release. Because Defendant was unable to post that bond, he was transferred to the custody of the Commissioner of Correction at a prison while awaiting trial on the new charges. Defendant appealed. The Supreme Court affirmed, holding that the trial court’s imposition of a monetary bond and, after Defendant was unable to post that bond, Defendant’s transfer to the custody of the Commissioner, did not violate Defendant’s constitutional rights to (1) bail, pursuant to the Connecticut Constitution; and (2) procedural due process, pursuant to the Fourteenth Amendment to the United States Constitution. View "State v. Anderson" on Justia Law

In connection with his charge of interfering with an officer, Defendant applied for, and was accepted into, an accelerated rehabilitation program. After the expiration of his probationary period in the program, Defendant moved to dismiss the charge of interfering with an officer. The trial court denied the motion, finding that Defendant failed to satisfactorily complete the program because he was convicted of several unrelated crimes while participating in the program. Defendant appealed, arguing that the trial court did not have the discretion to consider the convictions because the conduct underlying the convictions took place before he was admitted into the program. The Supreme Court affirmed, holding that the purpose of the accelerated rehabilitation statute is to grant onetime offenders an opportunity to maintain a clean criminal record, and therefore, a conviction obtained while participating in the program is contrary to the purpose of the statute and requires a finding of unsatisfactory completion. View "State v. Kevalis" on Justia Law

After a jury trial, Defendant was convicted of one count of sexual assault in the fourth degree. During trial, in seeking to imply that the complainant had a motive to testify favorably for the State, Defendant sought to question the complainant on recross-examination about the conditions of her participation in a pretrial diversionary program on a felony charge pending against her in an unrelated case. The trial court concluded that the prejudicial effect of the proffered evidence was greater than its probative value. The Appellate Court reversed the conviction, concluding that the trial court violated Defendant’s right to confrontation by precluding Defendant from eliciting such evidence. The Supreme Court reversed, holding that Defendant failed to establish a sufficient nexus between the testimony he sought to obtain and the complainant’s motive to testify favorably for the State to implicate his right to confrontation. View "State v. Benedict" on Justia Law

Defendant was charged with one count of murder and related crimes for his role in the shooting death of Aaron McCrea. At trial, Defendant sought to introduce witness statements contained in a search warrant affidavit that purportedly implicated other individuals in the shooting. The trial court sustained the State’s objection, concluding that the statements constituted inadmissible hearsay. Defendant was subsequently convicted of all charges. Defendant appealed, arguing that he functionally preserved his claim that the statements in the search warrant affidavit should have been admitted under one of the hearsay exceptions and, in the alternative, his claim should be reviewed pursuant to State v. Golding. The Supreme Court rejected both of Defendant’s arguments, holding (1) Defendant failed to preserve his claim, functionally or otherwise; and (2) the claim was not of a constitutional nature such that review was warranted pursuant to Golding. View "State v. Santana" on Justia Law