Justia Criminal Law Opinion Summaries

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

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