Justia Criminal Law Opinion Summaries

The Supreme Court reversed the judgment of the appellate court concluding that the State had demonstrated good cause to amend its information during trial and that Defendant's substantive rights would not be prejudiced by the late amendment, holding that a new trial was required.After a jury trial, Defendant was convicted of two counts each of sexual assault in the first degree and sexual assault in the fourth degree and of three counts of risk of injury to a child. Defendant appealed, arguing that the trial court abused its discretion when it allowed the State to amend its information after the commencement of trial even though the State was aware that the time frame alleged in its information was inaccurate. The appellate court affirmed. The Supreme Court reversed, holding that the trial court abused its discretion in permitting the State's late amendment to its information. View "State v. Peluso" on Justia Law

The Supreme Court reversed the judgment of the appellate court dismissing Petitioner's appeal from the judgment of the habeas court denying his petition for a writ of habeas corpus, holding that Petitioner failed to prove his claim that his counsel labored under an actual conflict of interest.At issue was whether the habeas court abused its discretion in denying Petitioner's petition for certification to appeal with respect to his claim that his defense counsel rendered ineffective assistance during his second criminal trial by simultaneously working as defense counsel and as an active duty police officer in a different city, which Petitioner claimed was a conflict of interest. The Supreme Court affirmed, holding that defense counsel's actions did not rise to the level of an actual conflict of interest for purposes of the Sixth Amendment. View "Diaz v. Commissioner of Correction" on Justia Law

The Supreme Court affirmed Defendant's conviction of murder, conspiracy to commit murder, and first degree assault, holding that the reversal of a codefendant's conviction does not necessitate the reversal of a defendant's conviction, despite the defendant's failure to preserve the issue at trial when the codefendant and defendant were jointly tried and the codefendant properly preserved the issue.Defendant's codefendant was granted a new trial premised on his objection to the State's untimely disclosure of an expert witness. Even though Defendant did not join in on his codefendant's objection to the untimely disclosed expert Defendant argued in this appeal that the Supreme Court should exercise its supervisory authority to reverse his conviction in the interest of justice. The Supreme Court affirmed, holding (1) fairness and justice do not require reversal of Defendant's conviction; and (2) this Court declines to overrule its decision in State v. Turner, 224 A.3d 129 (Conn. 2020), to review the merits of Defendant's unpreserved claim under State v. Edwards, 156 A.3d 506 (Conn. 2017). View "State v. Rogers" on Justia Law

The Supreme Court affirmed the judgment of the appellate court affirming Defendant's conviction of one count of conspiracy to sell narcotics and two counts of possession of narcotics with intent to sell, holding that Defendant was not entitled to reversal on his claims of error.On appeal, Defendant argued that the trial court erred in admitting expert testimony regarding his intent to sell narcotics and in admitting evidence that he had no reportage wages on record with the Connecticut Department of Labor in 2016 and 2017. The Supreme Court affirmed, holding (1) Defendant failed to preserve his first evidentiary claim; and (2) assuming, without deciding, that the trial court improperly admitted evidence regarding Defendant's lack of reportable wages, Defendant failed to demonstrate that the error substantially swayed the verdict. View "State v. Qayyum" on Justia Law

The Supreme Court affirmed Defendant's conviction of murder in violation of Conn. Gen. Stat. 53a-54a, holding that the trial court did not abuse its discretion by admitting evidence of uncharged misconduct, namely, two prior shootings involving the alleged murder weapon, to prove identity and means.On appeal, Defendant argued that the evidence was not relevant or material to identity and that the probative value of the evidence was outweighed by its prejudicial effect. The Supreme Court disagreed and affirmed, holding that, given the manner in which the testimony was limited and the numerous cautionary instructions given to the jurors, the trial court did not abuse its discretion in admitting the uncharged misconduct evidence. View "State v. Patterson" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the trial convicting Defendant of various crimes arising from five criminal cases, which included first degree robbery, second degree arson, and attempt to commit murder, holding that the trial court erred in denying Defendant's motion to suppress.At issue on appeal was the trial court's denial of Defendant's motion to suppress evidence discovered during a search of his cell phone and evidence obtained from his cell phone service provider. Specifically in question was whether the warrants authorizing those searches were supported by probable cause and whether they particularly described the place to be searched and the things to be seized. The Supreme Court reversed in part, holding (1) the trial court erred in denying Defendant's motion to suppress the information obtained from the execution of both warrants; and (2) this error was harmless with respect to some, but not all, of the crimes alleged in the indictment. View "State v. Smith" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of felony murder, robbery in the first degree, and other crimes, holding that any error in the trial court's failure to suppress evidence obtained from a search warrant was harmless.On appeal, Defendant challenged the trial court's denial of his motion to suppress evidence obtained from a search of his cell phone, arguing that the application for the warrant authorizing the search lacked a particular description of the items to be seized and that the affidavit supporting the application failed to establish probable cause. The Supreme Court affirmed, holding that the State met its burden of showing that any error in the denial of Defendant's motion to suppress was harmless beyond a reasonable doubt. View "State v. Bowden" on Justia Law

The Supreme Court affirmed Defendant's convictions of murder, assault in the first degree by means of the discharge of a firearm, and attempt to commit assault in the first degree by means of the discharge of a firearm, holding that there was no violation of Defendant's Fourth Amendment rights in this case.On appeal, Defendant argued that the trial court erred in denying his motion to suppress evidence seized from his father on the grounds that the police officers' warrantless entry into the residence home under the emergency exception to the Fourth Amendment warrant requirement was justified. Alternatively, the court deterred that, even if the initial entry was unlawful, Defendant's shooting of the victim sufficiently attenuated that unlawful act from the subsequent lawful search and seizure of the evidence at issue. The Supreme Court affirmed, holding that (1) under the totality of the circumstances, it was objectively reasonable for the officers to conclude that there was an emergency justifying their initial entry into the residence; and (2) in light of this conclusion, the subsequent entries were similarly justified. View "State v. Samuolis" on Justia Law

The Supreme Court affirmed the judgment of the trial court on remand determining that Defendant had failed to establish that defense counsel, Kirstin Coffin, had a conflict of interest, holding that there was no error.Defendant was convicted of murder and sentenced to a fifty-year term of incarceration. On appeal, the Supreme Court held that the trial court had a duty to inquire into Coffin's alleged conflict of interest and remanded for a determination as to whether Defendant's claim had merit. After a hearing on remand, the trial court concluded that Defendant had failed to establish that Coffin was burdened by an actual conflict of interest as a result of her prior representation of Defendant. The Supreme Court affirmed, holding (1) there was no error in the determination that Coffin was not burdened by an actual conflict of interest that adversely affected her performance; and (2) Defendant's remaining claim was without merit. View "State v. Davis" on Justia Law

The Supreme Court dismissed as moot Defendant's appeal from the judgment of conviction, rendered after a jury trial, of murder and criminal possession of a firearm by a convicted felon, holding that Defendant was not entitled to relief.On appeal, Defendant argued that the trial court violated his Sixth Amendment right to present a defense by precluding an expert witness proffered by defense counsel from testifying as to Defendant's location during certain relevant time periods on the basis of cell phone carrier data. The Supreme Court dismissed Defendant's appeal, holding (1) Defendant failed to challenge all of the independent bases of the trial court's evidentiary ruling; and (2) therefore, this Court could not provide Defendant practical relief. View "State v. Council" on Justia Law