Justia Criminal Law Opinion Summaries

Defendant’s conviction for threatening in the second degree and breach of the peace in the second degree arose out of statements he made to an attorney that represented the Town of Waterford in a zoning dispute with Defendant. On appeal, Defendant argued that his statements were protected by the First Amendment to the Federal Constitution because they were not real or true threats. The Appellate Court affirmed. The Supreme Court reversed, holding that Defendant was entitled to a judgment of acquittal on both charges, as Defendant’s statements did not rise to the level of a true threat and were therefore entitled to the protection of the First Amendment despite their inflammatory nature. View "State v. Krijger" on Justia Law

After a jury trial, Petitioner was convicted of sexual assault in the first degree and risk of injury to a child. The Appellate Court affirmed the convictions on direct appeal. Petitioner later sought habeas relief, claiming that his appellate counsel provided ineffective assistance by failing to investigate Petitioner’s claims that he had a history of sexually transmitted diseases and to introduce evidence concerning whether the victim had contracted any such diseases. The habeas court rejected Petitioner’s claim. The Appellate Court affirmed. The Supreme Court affirmed, holding that Petitioner failed to demonstrate that he was prejudiced by any deficiency in counsel’s performance. View "Anderson v. Comm'r of Corr." on Justia Law

After a jury trial, Defendant was convicted of one count of murder and one count of felony murder. The Supreme Court affirmed, holding that the trial court (1) properly admitted evidence of uncharged sexual misconduct; (2) properly rejected Defendant’s claim under Brady v. Maryland that he was denied a fair trial because the state failed to disclose an alleged agreement or understanding with a key witness that she would be given a benefit if she testified for the state, as there was no agreement or understanding between the witness and the state prior to her testimony; and (3) properly permitted the prosecutor to exercise a peremptory challenge with respect to an African-American venireperson. View "State v. Smith" on Justia Law

After a jury trial, Defendant was convicted of operating a motor vehicle while under the influence of intoxicating liquor or drugs or both. Defendant appealed, arguing that the trial court abused its discretion by disallowing certain demonstrative evidence proffered by Defendant, by which Defendant sought to demonstrate to the jury how his alleged disability prevented him from performing two mobility based field sobriety tests under any conditions. The Appellate Court affirmed. The Supreme Court affirmed, holding that, rather than preventing Defendant from presenting his defense, the trial court did not abuse its discretion in disallowing Defendant from utilizing a display that the court properly deemed unreliable to pursue his theory of defense. View "State v. Romanko" on Justia Law

Defendant was convicted after a jury trial of one count of felony murder. The Supreme Court affirmed, holding (1) the trial court’s decision to preclude the testimony of a key defense witness did not rise to the level of a constitutional violation, nor was it improper on purely evidentiary grounds; (2) Defendant’s claims of prosecutorial impropriety during cross-examination and closing argument were without merit; (3) Defendant’s argument that his conviction was fundamentally unfair because the State relied on a different theory in his case than in the case against an alleged coassailant was without merit; (4) the evidence was sufficient to support Defendant’s conviction for felony murder; and (5) the trial court did not err in denying Defendant’s motion to suppress oral and written statements to the police confessing his role in the murder. View "State v. Andrews" on Justia Law

After a jury trial, Defendant was convicted of operating a motor vehicle while under the influence of intoxicating liquor and operating a motor vehicle while having an elevated blood alcohol content. Defendant was also convicted of speeding. The Supreme Court affirmed the judgment of the trial court, holding (1) the trial court properly denied Defendant’s motion to suppress breath test reports, as the state experts who testified regarding certain breath tests fulfilled the requirements of Melendez-Diaz v. Massachusetts; and (2) the trial court properly denied Defendant’s motion to suppress the evidence resulting from his arrest, as the constable who made the arrest in the present case was a duly qualified special constable with the power to make the arrest. View "State v. Buckland" on Justia Law

Defendant was convicted on a conditional plea of nolo contendere of possession of narcotics with intent to sell. Defendant appealed the district court’s denial of his motion to suppress evidence that the police discovered after stopping Defendant incident to the detention of another individual, who was wanted for a violation of probation, while Defendant and the individual were walking together on a sidewalk. Defendant appealed, arguing that the officers had seized him in violation of Terry v. Ohio because they lacked a reasonable and articulable suspicion that Defendant had committed or was about to commit a crime. The Appellate Court affirmed the denial of Defendant’s motion to suppress, concluding that it is permissible for the police to briefly detain the companion of a suspect, incident to the lawful stop of the suspect, even though the police lack reasonable suspicion to believe the companion has engaged in or is engaging in criminal behavior. The Supreme Court affirmed, holding that the police were authorized to stop and briefly detain Defendant, as a reasonable safety measure, in connection with the lawful detention of the individual he was accompanying because the police reasonable believed that the other individual was armed and dangerous. View "State v. Kelly" on Justia Law

Respondent was charged as a juvenile with several firearms-related offenses. The State filed a motion seeking a discretionary transfer of Respondent’s case to the regular criminal docket of the superior court pursuant to Conn. Gen. Stat. 46b-127(b)(1). The trial court granted the State’s motion. Respondent appealed. The Appellate Court dismissed the appeal for lack of a final judgment. The Supreme Court affirmed, holding that the a transfer order made pursuant to the discretionary transfer provision in section 46b-127(b)(1) is not a final judgment for purposes of appeal, as the clear intent of the Legislature is to prohibit interlocutory appeals from discretionary transfer orders. View "In re Tyriq T." on Justia Law

After a jury trial, Defendant was convicted of murder, two counts of kidnapping in the second degree, and assault in the third degree. Defendant appealed, arguing that the trial court abused its discretion in joining his two cases for trial and that the evidence was insufficient was support his conviction of both counts of kidnapping in the second degree. The Supreme Court affirmed in part and reversed in part, holding (1) the trial court did not err in joining the two cases; (2) the evidence was sufficient to support the judgment of conviction of one count of second degree kidnapping and the assault conviction; but (3) the jury could not reasonably have found that two separate instances of kidnapping occurred. Remanded with direction to render a judgment of acquittal on one count of kidnapping in the second degree. View "State v. Crenshaw" on Justia Law

After a jury trial, Defendant was convicted of murder and sentenced to fifty years imprisonment. Defendant appealed, contending that he had been deprived of a fair trial because of improper statements made by the prosecutor during trial and in closing argument. The Appellate Court affirmed the judgment of conviction, concluding that only certain statements by the prosecutor were improper, and Defendant was not deprived of a fair trial as a result. Defendant and the State separately appealed. The Supreme Court affirmed, holding (1) the State’s appeal must be dismissed because the State was not aggrieved by the judgment of the Appellate Court; and (2) Defendant was not deprived of a fair trial. View "State v. Albino" on Justia Law