Justia Civil Rights Opinion Summaries

Articles Posted in Connecticut Supreme Court
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The Supreme Court affirmed the judgment of the Appellate Court affirming the judgment of the trial court denying Defendant's motion to suppress evidence of a firearm that police seized during an investigatory stop, holding that the patdown of Defendant was supported by reasonable and articulable suspicion. Defendant entered a conditional plea of solo contenders to one count of carrying a pistol without a permit and one count of criminal possession of a pistol or revolver. The Appellate Court affirmed the judgment of the trial court denying Defendant's motion to suppress, holding that the trial court properly concluded that the patdown of Defendant was supported by reasonable and articulable suspicion that he might be dangerous. The Supreme Court affirmed, holding that the Appellate Court correctly concluded that the trial court properly determined that the patdown of Defendant was lawful under both the federal and state constitutions. View "State v. Lewis" on Justia Law

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The Supreme Court affirmed the judgment of the habeas court denying Petitioner's second petition for a writ of habeas corpus challenging his 1998 murder conviction, holding that the habeas court properly denied the petition. Specifically, the Court held (1) the habeas court correctly concluded that Petitioner failed to establish that he was actually innocent of the murder; (2) the habeas court properly determined that the identification procedures employed in this criminal case did not violate Petitioner's due process rights; (3) the habeas court correctly concluded Petitioner's first habeas counsel did not provide ineffective assistance of counsel; and (4) assuming, for the sake of argument, that the habeas court should have resolved Petitioner's cruel and unusual claims on the merits, Petitioner could not prevail on those claims, and therefore, it need to be determined whether the habeas court improperly applied the doctrine of res judicata. View "Bowens v. Commissioner of Correction" on Justia Law

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The Supreme Court affirmed the judgment of the habeas court rendering judgment against Petitioner, a juvenile offender, on his claim that the evolution of Connecticut's "standards of decency" regarding acceptable punishments for children who engage in criminal conduct has rendered the transfer of his case to the regular criminal docket and resultant sentencing unconstitutional, holding that Petitioner was not entitled to relief on his claims. Petitioner, who was fourteen years old when he committed felony murder, argued that his sentence as an adult after his case was automatically transferred to the regular criminal docket violated the state prohibition against cruel and unusual punishment. The habeas court denied relief. The Supreme Court affirmed, holding (1) transferring the case of a fourteen year old defendant to the regular criminal docket comports with evolving standards of decency and, therefore, does not violate the Connecticut constitution; and (2) Petitioner's forty year sentence does not violate the constitutional prohibition against cruel and unusual punishment after the provisions of P.A. 15-84 made Petitioner eligible for parole after serving sixty percent of his original sentence. View "Griffin v. Commissioner of Correction" on Justia Law

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The Supreme Court affirmed the decision of the Appellate Court affirming the trial court's dismissal of Defendant's motion to correct an illegal sentence, holding that because Defendant is now eligible for parole under No. 15-84 of the 2015 Public Acts (P.A. 15-84) the Connecticut constitution did not require a resentencing of his unconstitutional sentence. Defendant, a juvenile offender, was convicted of murder and sentenced to thirty-five years' imprisonment. At the time of sentence, Defendant was indelible for parole. Thereafter, decisions by the United States and Connecticut Supreme Courts and enactments by the legislature resulted in changes to the sentencing scheme for juvenile offenders. To comply with federal constitutional requirements the legislature passed P.A. 15-84. As a result, Defendant will be parole eligible after serving twenty-one years. Thereafter, Defendant filed a motion to correct an illegal sentence, asserting a violation of Miller v. Alabama, 467 U.S. 460 (2012). The trial court dismissed the motion for lack of jurisdiction. The Appellate Court ultimately affirmed on the ground decided in State v. Delgado, 151 A.3d 345 (Conn. 2016). The Supreme Court affirmed, holding that, consistent with Delgado and the federal constitution, Defendant's parole eligibility afforded by P.A. 15-84, 1 was an adequate remedy for the Miller violation. View "State v. Williams-Bey" on Justia Law

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The Supreme Court affirmed the judgment of the appellate court affirming the judgment of the trial court denying Defendant's motion to correct an illegal sentence, holding that the legislature may and has remedied the constitutional violation in this case with parole eligibility. Defendant, a juvenile offender, was convicted of murder and other offenses. Defendant was originally sentenced to imprisonment for the functional equivalent of his lifetime without the possibility of parole. Subsequently, decisions by the United States and Connecticut Supreme Courts and enactments by the legislature resulted in changes to the sentencing scheme for juvenile offenders. As a result, Defendant will be parole eligible when he is about fifty years old. Defendant filed a motion to correct an illegal sentence based on Miller v. Alabama, 467 U.S. 460 (2012). The trial court ultimately dismissed the motion, concluding that Defendant's claim was moot in light of the United States Supreme Court's holding that Miller applied retroactively. The Supreme Court affirmed, holding (1) parole eligibility afforded by No. 15-84 of the 2015 Public Acts (P.A. 15-84) is an adequate remedy for a Miller violation under the Connecticut constitution; and (2) P.A. 15-84, 1 does not violate the separation of powers doctrine or Defendant's right to equal protection under the federal constitution. View "State v. McCleese" on Justia Law

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The Supreme Court affirmed the judgment of the appellate court upholding Defendant's convictions for several offenses stemming from the sexual assault of his minor daughter, holding that the evidence was sufficient to support Defendant's conviction for three counts of criminal violation of a restraining order and that the prosecutor did not commit misconduct. Specifically, the Court held (1) there was sufficient evidence from which the jury could conclude that Defendant had "knowledge of the terms of the order" because the court expressly instructed Defendant to limit contact with the children and Defendant heard Spanish language translations of the terms of the order; and (2) the prosecutor's comments and questions were not improper. View "State v. Elmer G." on Justia Law

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The Supreme Court reversed in part the judgment of the Appellate Court concluding that Defendant failed to establish that his Sixth Amendment right to confront witnesses against him was violated at trial, holding that, under the specific circumstances of this case, Defendant established a violation of his right to confrontation. Defendant was found guilty of felony murder, manslaughter in the first degree with a firearm, and other offenses. At trial, the State introduced evidence that Defendant's DNA profile, which had been generated from a post arrest buccal swab, matched the DNA found on evidence from the crime scene. The State, however, did not call as a witness the analyst who processed the buccal swab and generated the DNA profile used in the comparison. On appeal, the Appellate Court concluded that Defendant's Sixth Amendment claim failed because the admission of DNA evidence did not violate Defendant's constitutional right to confrontation. The Supreme Court reversed, holding that the generation of DNA's profile was testimonial and that Defendant's Sixth Amendment right to confront witnesses against him was violated. View "State v. Walker" on Justia Law

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The Supreme Court affirmed the judgment of the Appellate Court dismissing Appellant's appeal from the judgment of the habeas court denying Appellant's amended petition for a writ of habeas corpus, holding that Appellant failed to meet his burden of showing that his criminal trial counsel rendered ineffective assistance by failing to present the testimony of a second alibi witness to support his defense. On appeal, Appellant claimed that the Appellate Court incorrectly concluded that the habeas court did not abuse its discretion in denying certification to appeal because he established that his counsel had performed deficiently. The Supreme Court disagreed, holding (1) it was not debatable among jurists of reason that Appellant rendered ineffective assistance; and (2) therefore, the Appellate Court correctly concluded that the habeas court did not abuse its discretion in denying Appellant's petition for certification to appeal. View "Meletrich v. Commissioner of Correction" on Justia Law

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The Supreme Court affirmed the judgment of the trial court determining that Plaintiff's various statements and gestures regarding gun violence and mass shootings that led to his expulsion from the university were true threats that were not protected by the First Amendment to the United States Constitution, holding that Plaintiff's statements and gestures made on a public university campus were true threats. A university expelled Plaintiff from the university's campus after finding that Plaintiff's statements and actions with respect to gun violence had violated four provisions of the university's student code of conduct. Plaintiff brought this action alleging, among other things, that his expulsion violated his constitutional rights to due process and to freedom of speech. The trial court entered judgment in favor of Defendants. Plaintiff appealed, asserting that his statements and gestures were hyperbolic and humorous statements on a matter of public concern. The Supreme Court disagreed, holding that Plaintiff's statements and gestures were true threats that were not protected by the First Amendment. View "Haughwout v. Tordenti" on Justia Law

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The Supreme Court affirmed Defendant's conviction of sexual assault in a cohabiting relationship, holding that alleged improper comments made by the prosecutor during closing argument and cross-examination did not warrant reversal of Defendant's conviction. On appeal, Defendant argued that the prosecutor made an impermissible "generic tailoring" argument by commenting in closing argument that the jury should discredit Defendant's trial testimony and that this comment violated his confrontation rights under the Connecticut Constitution. Defendant further argued that the prosecutor engaged in impermissible conduct in violation of his due process right to a fair trial pursuant to State v. Singh, 793 A.2d 226 (Conn. 2002). The Supreme Court affirmed, holding (1) the prosecutor's tailoring comment constituted a specific, rather than a generic, tailoring argument; and (2) assuming that Singh was violated, Defendant was not deprived of his due process right to a fair trial. View "State v. Weatherspoon" on Justia Law