Justia Criminal Law Opinion Summaries

Defendant was charged with murder, among other crimes. Defendant, who was indigent, waived his right to appointed counsel and elected to represent himself. Defendant requested that the trial court order funding so that he could retain experts and an investigator in order to present a defense. The parties subsequently entered into a joint stipulation requesting the trial court to reserve questions of law to the Supreme Court regarding the funding issue. The Supreme Court answered (1) an indigent self-represented defendant is constitutionally entitled to expert or investigative services at public expense, provided that he makes a threshold showing that such assistance is reasonably necessary to formulate and present a defense; (2) the trial court does not retain the discretion to authorize public expenditures for any such expert witness or investigator; and (3) the public funds should come from the State’s Office of the Chief Public Defender. View "State v. Wang" on Justia Law

After a jury trial, Defendant was convicted of sexual assault in the first degree and risk of injury to a child. The Supreme Court reversed the judgment of the trial court and remanded for a new trial, holding (1) the trial court abused its discretion by improperly precluding Defendant from introducing, on relevancy grounds, evidence of prior sexual conduct that was admissible under the rape shield statute, in violation of Defendant’s federal and state constitutional rights to confrontation; and (2) the trial court’s preclusion of the evidence was not harmless beyond a reasonable doubt. View "State v. Shaw" on Justia Law

After a jury trial, Defendant was convicted of several crimes. On appeal, Defendant argued that, during sentencing, the trial court deprived him of his due process rights by improperly considering that Defendant decided to proceed to trial rather than accept a plea bargain. The Appellate Court declined to review Defendant’s sentencing claim on the grounds that it was unpreserved and that Defendant had not properly made an “affirmative request” for review in his main brief under State v. Golding. The Supreme Court reversed in part, holding (1) the requirement that a defendant must “affirmatively request” Golding review in his main brief in order to receive appellate review of unpreserved constitutional claims is overruled, and therefore, the Appellate Court improperly declined to review Defendant’s constitutional claims on that ground; (2) Defendant failed to establish that the trial court penalized him for exercising his right to a jury trial; but (3) the use of the Court’s supervisory authority was warranted to prevent adverse effects on the public’s perception of the inherent fairness of the criminal justice system that may arise when a trial judge could appear to have considered a defendant’s decision to exercise his right to a trial during sentencing. Remanded for a new sentencing hearing. View "State v. Elson" on Justia Law

After a jury trial, Defendant was convicted of murder and other crimes. The Supreme Court (1) reversed the judgment of the trial court as to Defendant’s convictions for the crimes of kidnapping in the second degree and burglary in the first degree, holding that certain evidence relating to the potential impeachment of a key prosecution witness should have been admitted at trial, and that the failure to admit the evidence was not harmless beyond a reasonable doubt as to those counts; and (2) affirmed the trial court in all other respects, holding that the court did not err in its instructions to the jury and that the prosecutor did not engage in misconduct. View "State v. Baltas" on Justia Law

Defendant pled nolo contendere to possession of narcotics with intent to sell to sell by a person who is not drug-dependent, possession of narcotics with intent to sell within 1500 feet of a school, and possession of a weapon in a motor vehicle. Defendant appealed, arguing that the trial court erred in denying his motion to suppress with respect to the narcotics and handgun found in a plastic bag inside the trunk of his vehicle. Specifically, Defendant argued that the search of bags inside the trunk of his vehicle could not be conducted within the automobile exception to the warrant requirement under the Connecticut constitution. The Supreme Court affirmed, holding that the state constitution does not prohibit the warrantless search of a closed container located in the trunk of a vehicle conducted during an otherwise constitutional warrantless search of a vehicle. View "State v. Williams" on Justia Law

Upon responding to a 911 call from a tenant of a rooming house reporting a disturbance involving a gun, police officers entered an unlocked attic space in the house and retrieved marijuana and a gun. After a jury trial, Defendant, who resided in a room on the third floor of the house, was convicted of attempt to commit criminal possession of a firearm, criminal possession of a pistol, and possession of marijuana with intent to distribute. Defendant appealed the denial of his motion to suppress the evidence seized by the police as products of an unlawful search, claiming he had a reasonable expectation of privacy in the attic. The appellate court affirmed, holding that, because of Defendant’s lack of control over the access of others to the attic, Defendant did not have an expectation of privacy in that space that society would recognize as reasonable. The Supreme Court affirmed, holding that appellate court properly resolved the issue by virtue of its well-reasoned decision. View "State v. Pierre" on Justia Law

Upon following up on complaints from Defendant’s neighbor relating to Defendant’s keeping of animals in his residence, a police officer concluded that a “welfare check” was necessary and made a warrantless entry into Defendant’s home. Defendant subsequently entered a plea of nolo contendere to two counts of cruelty to animals. Defendant appealed the trial court’s denial of his motion to suppress on the ground that the warrantless entry was justified under the emergency exception to the warrant requirement. The appellate court reversed, concluding that the evidence did not permit a finding that the police reasonably believed that a warrantless entry was necessary to help a person inside the dwelling who was in immediate need of assistance. The Supreme Court reversed, holding that the trial court properly concluded that, under the totality of the circumstances present in this case, a police officer reasonably would have believed that an emergency existed inside Defendant’s home. View "State v. DeMarco" on Justia Law

After a jury trial, Defendant was convicted of committing the crime of robbery in the first degree. In its information charging Defendant, the state alleged that Defendant was armed with a firearm during the commission of the crime. During trial, however, the court instructed the jury that Defendant could be found guilty if all other elements of the crime had been proven and if any person participating in the commission of the crime possessed a firearm. Defendant appealed, arguing that the trial court improperly instructed the jury that it could find him guilty under a theory of liability not set forth in the State’s information. Because Defendant did not preserve his claim for appellate review by objecting to the jury instruction, he sought review under State v. Golding. The appellate court declined to review Defendant’s claim on appeal, concluding that Defendant had implicitly waived any objection to the jury instructions under the rule set forth in State v. Kitchens. The Supreme Court reversed, holding that Defendant did not implicitly waive his claim because he was never provided with the court’s actual proposed charge and consequently did not have a meaningful opportunity to review the instructions. View "State v. Davis" on Justia Law

After a jury trial, Defendant was convicted of manslaughter in the first degree with a firearm as an accessory, among other crimes. The convictions arose from a shooting that occurred during an altercation in a housing complex. The appellate court reversed the manslaughter conviction, concluding that insufficient evidence supported the conclusion that Defendant acted as an accessory by intentionally aiding Donald Wilson, the person who fired the fatal shots. The Supreme Court affirmed, holding that the record contained insufficient evidence to prove that Defendant assisted Wilson in the commission of the homicide. View "State v. Gonzalez" on Justia Law

Defendant was convicted of sixteen federal felony offenses arising from actions he took while acting as the mayor of Bridgeport. After his release from prison, Defendant applied for reinstatement to the bar. The local standing committee issued a report in which it concluded that Defendant was fit to practice law and recommended that he be reinstated. The trial court denied Defendant’s application, concluding that the record did not substantiate a finding of good moral character and fitness to practice law. The Supreme Court affirmed, holding that the trial court properly concluded that the standing committee abused its discretion when it determined that Defendant was presently fit to practice law and recommended his reinstatement. View "State Grievance Comm. v. Ganim" on Justia Law