Justia Civil Rights Opinion Summaries

Defendant entered a conditional plea of nolo contendere to possession of a controlled substance with intent to sell. Prior to entering the plea, Defendant moved to suppress evidence seized from his vehicle, claiming that the police did not possess a reasonable and articulable suspicion that he was engaged in or about to engage in criminal activity. On appeal, Defendant challenged the the trial court’s denial of his motion to suppress. The Appellate Court reversed, concluding that the trial court’s determination that the police possessed a reasonable and articulable suspicion that criminal activity was afoot when they detained Defendant was incorrect. The Supreme Court reversed, holding that, under the totality of the circumstances, the police possessed a reasonable and articulable suspicion to detain Defendant outside a known drug location where Defendant had previously acted in a manner consistent with drug activity. View "State v. Peterson" on Justia Law

Defendant pleaded guilty to harassment in the second degree and criminal trespass in the first degree and was sentenced to one year incarceration, execution suspended, and two years of probation. Defendant was later charged with violating the conditions of his probation. After a hearing, the trial court found that Defendant violated the conditions of his probation, continued Defendant’s probation, and added new conditions. The Supreme Court affirmed, holding (1) the trial court properly admitted evidence that Defendant argued should have been suppressed; (2) the evidence was sufficient to demonstrate that Defendant violated the terms of his probation; (3) the trial court did not err in admitting certain hearsay evidence; and (4) Defendant waived his Second Amendment right to possess firearms when he agreed to the condition of his probation barring him from possessing firearms. View "State v. Maietta" on Justia Law

After a jury trial, Defendant was convicted in two consolidated cases of attempted murder, two counts of risk of injury to a child, and murder. The Supreme Court reversed, concluding that the trial court improperly granted the State’s motion to disqualify his chosen attorney, Gary Mastronardi, and that the improper disqualification was structural error requiring a new trial. On remand, Defendant filed a motion asking the State to fund Mastronardi’s private fee or, alternatively, to dismiss the charges against him on the grounds that he was now indigent and tat Mastronardi would not represent him at the new trial at the rate paid to assigned counsel by the Division of Public Defender Services. The trial court denied Defendant’s motion, concluding that the Supreme Court’s decision Peeler I did not require it. After a second jury trial, Defendant was found guilty on all counts. The Supreme Court affirmed, holding that the trial court did not violate Defendant’s right to counsel of choice at his new trial by denying his funding motion. View "State v. Peeler" on Justia Law

After a jury trial, Defendant was convicted of crimes committing during a string of armed robberies in the cities of Stamford and Norwalk and the town of Greenwich. Defendant appealed, arguing (1) his constitutional right to counsel was violated when the trial court admitted incriminating statements he made regarding the Norwalk and Greenwich robberies while he was represented by counsel in the case involving the Stamford robbery; and (2) the trial court violated his constitutional right to confrontation by restricting defense counsel’s cross-examination of a key prosecution witness. The Supreme Court affirmed, holding that the trial court’s admission of the incriminating statements and its restrictions on counsel’s cross-examination of the witness did not violate Defendant’s Sixth Amendment rights or constitute an abuse of discretion. View "State v. Leconte" on Justia Law

Defendant was convicted of murder, assault in the first degree, criminal possession of a pistol, and risk of injury to a child. Defendant appealed, arguing that the trial court abused its discretion in failing to conduct an inquiry into his claim of juror misconduct. The Supreme Court reversed and remanded with instructions for the trial court to conduct an inquiry into Defendant’s claim. After approximately a decade, the trial court held the required inquiry and found no evidence of juror misconduct. The Supreme Court affirmed, holding (1) the trial court did not err in concluding that there was no evidence of juror misconduct; and (2) the delay on remand did not violate Defendant’s due process rights. View "State v. Roman" on Justia Law

After a jury trial, Defendant was convicted of robbery in the first degree. Defendant appealed, asserting that the trial court erred in denying his motion for a mistrial on the ground that his mother had tampered with the jury by approaching a juror outside the courthouse and speaking to him about the evidence in the case. The Supreme Court affirmed, holding (1) the presumption of prejudice in jury tampering cases set forth by the United States Supreme Court in Remmer v. United States remains good law in cases of external interference with the jury’s deliberative process via private communication, contact, or tampering with jurors about the pending matter; and (2) the State carried its burden of proving that the actions of Defendant’s mother did not lead to the reasonable possibility that any juror’s ability to decide this case fairly and impartially was affected. View "State v. Berrios" on Justia Law

After a jury trial, Defendant was convicted of assault in the second degree. The Appellate Court reversed, concluding that that Defendant was entitled to a new trial due to certain alleged improprieties that the prosecutor committed during his cross-examination of Defendant and in closing argument. Both parties appealed. The Supreme Court reversed, holding (1) the Appellate Court incorrectly concluded that Defendant was substantially prejudiced by the improprieties at issue in this case; (2) the trial court properly instructed the jury on the initial aggressor exception to self-defense; and (3) the trial court properly denied Defendant’s motion to suppress evidence of the knife that Defendant used during the assault. View "State v. Jones" on Justia Law

Michael Aronow, an orthopedic surgeon at the University of Connecticut Health Center, filed a grievance with the Health Center Appeals Committee against Jay Lieberman, the chairman of the orthopedic surgery department at the Center, accusing Lieberman of attempted intimidation and harassment. Aronow requested copies of the Committee’s report of its findings regarding Aronow’s grievance as well as the report written by the president emeritus of the University, but the Center denied Aronow’s request, concluding that the reports were exempt from disclosure pursuant to Conn. Gen. Stat. 10a-154a. The Freedom of Information Commission, however, concluded that the reports were not exempt from disclosure under the statute and ordered the center to provide Aronow with a copy of the reports free of charge. The trial court dismissed Lieberman’s appeal, concluding that the Commission properly determined that the reports did not constitute a “record of the performance and evaluation” of a faculty member under section 10a-154a and were therefore not exempt from disclosure. The Supreme Court affirmed, holding that the reports in this case did not constitute a “record of the performance and evaluation” of a state university faculty or professional staff member within the exemption created by section 10a-154a. View "Lieberman v. Aronow" on Justia Law

Defendant was convicted of possession of narcotics with intent to sell and conspiracy to possess narcotics with intent to sell. The Appellate Court reversed and ordered a new trial, concluding that the prosecutor violated a court order concerning the permissible boundaries of argument and referred to facts outside the record, thus rendering the trial fundamentally unfair. The State appealed, claiming that the prosecutor’s remarks were not improper. The Supreme Court reversed, holding that one of the prosecutor’s arguments was improper, but this improper argument did not deprive Defendant of his due process right to a fair trial because there was no reasonable likelihood that the prosecutor’s comments affected the jury’s verdict. View "State v. Martinez" on Justia Law

After a jury trial, Defendant was convicted of two counts of aggravated sexual assault of a minor, in violation of Conn. Gen. Stat. 53a-70c(a)(1) and (6), and other offenses. Defendant sought review pursuant to State v. Golding, claiming that his convictions and sentences for two counts of aggravated sexual assault of a minor violate his right to be free of double jeopardy because they constitute multiple punishments for the same offense. The Supreme Court affirmed, holding that because subdivisions (1) and (6) of section 53a-70c(a) each require proof of a fact that the other does not, and because nothing in either the statutory text or legislative history of the statute reveals a contrary legislative intent, multiple convictions under section 53a-70c for the same transaction do not run afoul of the double jeopardy clause. View "State v. Wright" on Justia Law