Justia Civil Rights Opinion Summaries

Defendant was charged with several offenses after shooting Albert Weibel during an attempted robbery. Before trial, Defendant moved to preclude Weibel from making an in-court identification of Defendant, arguing that in-court identification procedures are unnecessarily suggestive. The trial court denied the motion pursuant to State v. Smith. During trial, Weibel identified Defendant as his assailant. The jury subsequently found Defendant guilty of conspiracy to commit robbery in the first degree and assault in the first degree. The Appellate Court affirmed. Defendant appealed, arguing that the Supreme Court should overrule the holding in Smith and hold that inherently suggestive in-court identifications are inadmissible even in the absence of a suggestive pretrial identification procedure. The Supreme Court affirmed, holding (1) first time in-court identifications must be prescreened for admissibility by the trial court; (2) Weibel’s in-court identification was a first time in-court identification and should have been prescreened, and the failure to follow the procedures outlined in this opinion potentially violated Defendant’s due process rights; but (3) any due process violation was harmless beyond a reasonable doubt. View "State v. Dickson" on Justia Law

After a jury trial, Defendant was convicted of murder. Defendant appealed, arguing that the trial court violated his right to present a defense by limiting his cross-examination of investigating police officers as to whether the murder investigation conformed to general police practices and/or standard police investigative procedures. The Appellate Court agreed with Defendant and reversed and remanded the case for a new trial. The Supreme Court reversed, holding that there was an absence of a sufficient offer of proof to such a line of inquiry, and therefore, the trial court did not improperly preclude Defendant’s inadequate investigation defense strategy. View "State v. Wright" on Justia Law

In 1992, Defendant was convicted of murder. In 2010, Defendant filed a third motion to correct an illegal sentence. The trial court denied the motion on the merits. Defendant appealed, arguing that the trial court violated his right to counsel by denying his request for the assistance of counsel without adhering to the procedure set forth in Anders v. California. The Appellate Court reversed the trial court’s denial of Defendant’s request for the appointment of counsel, holding that Anders applied to Defendant’s claim and that the requirements of Anders were not satisfied in this case. The Supreme Court affirmed, holding (1) the Anders procedure is not required to safeguard the statutory right to counsel in the context of a motion to correct an illegal sentence; but (2) the trial court erred by failing to appoint counsel to assist Defendant in determining whether a sound basis existed for him to file his motion, and the error was not harmless. View "State v. Francis" on Justia Law

The Commissioner of Children and Families (Petitioner) filed petitions to terminate the parental rights of Mother and Father (together, Respondents) to their two minor children. The trial court granted the petitions. Respondents appealed, claiming that the trial court erred in finding that Petitioner made reasonable efforts to reunify Respondents with their children and that Respondents were unable to unwilling to benefit from reunification efforts. The Supreme Court affirmed, holding (1) a finding that no reunification efforts were required is an independent basis upon which the trial court could have terminated the parental rights of Respondents; and (2) Respondents’ appeals would be moot because they did not timely appeal from that finding, but such a result would violate Respondents’ due process rights under the circumstances of this case. Remanded for a new trial. View "In re Egypt E." on Justia Law

After a jury trial, Petitioner was convicted of capital felony and other crimes. Petitioner was sentenced to death. Petitioner later filed a petition for a writ of habeas corpus, raising several challenges to his death sentence. The habeas court denied the petition. After Petitioner filed his appeal, the Supreme Court granted Petitioner permission to file a supplemental brief on the question of whether the legislature’s enactment of P.A. 12-5 rendered the death penalty, as applied to him and other similarly situated defendants, unconstitutional. While the appeal was pending, the Supreme Court decided State v. Santiago, which held that the imposition of the death penalty on defendants sentenced to death for capital crimes committed before the effective date of the legislation was unconstitutional under the state constitution. The Supreme Court reversed the denial of Petitioner’s habeas petition, holding that the death penalty was unconstitutional as applied to Petitioner. View "Webb v. Commissioner of Correction" on Justia Law

After a jury trial, Defendant was convicted of sexual assault in the first degree and sexual assault in the third degree. The Supreme Court affirmed, holding (1) the trial court properly denied Defendant’s motion to suppress statements he made to the police; (2) the trial court properly admitted evidence of uncharged sexual misconduct pursuant to State v. DeJesus; and (3) the trial court’s application of the Supreme Court’s decision in DeJesus and the relevant revision of section 4-5(b) of the Connecticut Code of Evidence did not violate Defendant’s equal protection rights under the federal and state constitutions. View "State v. Arias" on Justia Law

Brenda Puryear filed a complaint with the Commission on Human Rights and Opportunities on behalf of her minor daughter, Sarah, alleging that Echo Hose Ambulance and the city of Shelton had discriminated and retaliated against Sarah on the basis of her race and color in violation of the Connecticut Fair Employment Practices Act (CFEPA) and Title VII of the Civil Rights Act. The Commission’s human rights referee struck the complaint on the ground that Sarah was not an employee under the “remuneration test” used to resolve similar federal causes of action. The trial court dismissed the Commission’s appeal, concluding that the referee properly applied the remuneration test. The Appellate Court affirmed. The Commission appealed, arguing that the Appellate Court erred in applying the federal remuneration test rather than Connecticut’s common-law “right to control” test to determine whether an unpaid volunteer is an “employee” under the CFEPA. The Supreme Court affirmed, holding that the Appellate Court did not err in concluding that the remuneration test is the appropriate test for determining whether a volunteer is an employee under CFEPA. View "Commission on Human Rights & Opportunities v. Echo Hose Ambulance" on Justia Law

Defendant entered conditional pleas of nolo contendere to one count each of manufacturing a bomb and possession of child pornography in the first degree. Defendant appealed the trial court’s denial of his motion to suppress evidence discovered after the execution of an administrative search warrant at his apartment, arguing that the trial court erred in denying his motion because the administrative search warrant was invalid and improperly executed. The Supreme Court affirmed, holding that the administrative search warrant was valid because (1) the superior court judge who issued the administrative search warrant had the authority to issue the warrant; (2) the warrant was supported by the requisite probable cause; and (3) there was no error in the issuance of the warrant during an ex parte proceeding. Further, the search was lawful because excessive force was not used during its execution. View "State v. Saturno" on Justia Law

People for the Ethical Treatment of Animals, Inc. (Plaintiff) submitted a freedom of information request to the University of Connecticut Health Center (Defendant) for correspondence between Defendant and the National Institutes of Health regarding potential noncompliance with federal animal welfare guidelines. Defendant provided sixty-one pages of redacted records. The redactions were names of individuals who had violated federal protocols and federal grant identification numbers that could be used to identify those individuals. Plaintiff filed a complaint against Defendant with the Freedom of Information Commission (Commission). While the complaint was pending, the Commissioner of the Department of Administrative Services (Department) determined that there were reasonable grounds to believe that the disclosure of the redacted material could result in a safety risk. The Commission upheld the determination. The trial court sustained Plaintiff’s appeal, concluding that the Commission applied the wrong standard of review when it sustained Plaintiff’s appeal. The Supreme Court reversed, holding that the Commission applied the proper standard of review and properly upheld the Department’s determination. View "People for Ethical Treatment of Animals, Inc. v. Freedom of Info. Comm’n" on Justia Law

After a joint jury trial with his codefendant, Petitioner was convicted of ten charges arising from a murder and robbery. The Appellate Court affirmed. Petitioner thereafter filed a petition for a writ of habeas corpus, claiming that his trial counsel provided ineffective assistance by failing to conduct an adequate pretrial investigation and failing adequately to present a defense at trial. The habeas court granted the petition and ordered that Petitioner’s conviction be set aside, concluding that counsel’s failure to obtain information regarding a stolen cell phone before trial was deficient performance and that the deficient performance prejudiced Petitioner’s defense. The Supreme Court reversed, holding that counsel’s failure to investigate the issue of the stolen cell phone evidence was not prejudicial under Stickland v. Washington. View "Horn v. Comm’r of Corr." on Justia Law