Justia Civil Rights Opinion Summaries

Petitioner was convicted of sexual assault in the first degree and risk of injury to a child for sexually abusing a four-year-old girl. Petitioner subsequently filed a petition for a writ of habeas corpus, alleging that his counsel provided ineffective assistance by failing to present expert testimony regarding the suggestibility of young children and the reliability of a child’s recollection of sexual abuse. The habeas court reversed, concluding that Petitioner established that his trial counsel had rendered ineffective assistance. The Appellate Court affirmed. The Supreme Court reversed, holding that the failure of Petitioner’s trial counsel to present the expert testimony was objectively reasonable because there was a legitimate, strategic reason for not presenting such testimony. View "Michael T. v. Comm’r of Corr." on Justia Law

Pursuant to a plea agreement, Petitioner pleaded guilty to manslaughter in the first degree with a firearm. The plea agreement stated that Petitioner would receive a total sentence of between twenty and twenty-five years’ imprisonment and that defense counsel had a right to argue for a sentence beneath the twenty-five year cap. At sentencing, defense counsel agreed with the prosecutor’s recommendation that the trial court should impose the maximum sentence under the agreement. The trial court sentenced Petitioner to twenty-five years imprisonment. Petitioner subsequently filed a petition for a writ of habeas corpus, claiming ineffective assistance of counsel. The habeas court denied relief, determining that Petitioner failed to prove ineffective assistance of counsel under Strickland v. Washington. The Appellate Court affirmed, concluding that the habeas court properly determined that Petitioner failed to prove actual prejudice under Strickland. The Supreme Court reversed in part, holding that the habeas court improperly applied Strickland to Petitioner’s ineffective assistance claim because a complete breakdown in the adversarial process occurred, and therefore, Petitioner’s claim was instead controlled by United States v. Cronic, under which prejudice should be presumed. View "Davis v. Comm’r of Corr." on Justia Law

Defendant was found not guilty of certain offenses by reason of mental disease or defect and transferred to a maximum security psychiatric facility. Defendant was charged with new, violent crimes while housed at the facility. The trial court set a monetary bond as a condition of release. Because Defendant was unable to post that bond, he was transferred to the custody of the Commissioner of Correction at a prison while awaiting trial on the new charges. Defendant appealed. The Supreme Court affirmed, holding that the trial court’s imposition of a monetary bond and, after Defendant was unable to post that bond, Defendant’s transfer to the custody of the Commissioner, did not violate Defendant’s constitutional rights to (1) bail, pursuant to the Connecticut Constitution; and (2) procedural due process, pursuant to the Fourteenth Amendment to the United States Constitution. View "State v. Anderson" on Justia Law

After a jury trial, Defendant was convicted of operating a motor vehicle while under the influence of intoxicating liquor and operating a motor vehicle while having an elevated blood alcohol content. Defendant was also convicted of speeding. The Supreme Court affirmed the judgment of the trial court, holding (1) the trial court properly denied Defendant’s motion to suppress breath test reports, as the state experts who testified regarding certain breath tests fulfilled the requirements of Melendez-Diaz v. Massachusetts; and (2) the trial court properly denied Defendant’s motion to suppress the evidence resulting from his arrest, as the constable who made the arrest in the present case was a duly qualified special constable with the power to make the arrest. View "State v. Buckland" on Justia Law

Defendant was convicted on a conditional plea of nolo contendere of possession of narcotics with intent to sell. Defendant appealed the district court’s denial of his motion to suppress evidence that the police discovered after stopping Defendant incident to the detention of another individual, who was wanted for a violation of probation, while Defendant and the individual were walking together on a sidewalk. Defendant appealed, arguing that the officers had seized him in violation of Terry v. Ohio because they lacked a reasonable and articulable suspicion that Defendant had committed or was about to commit a crime. The Appellate Court affirmed the denial of Defendant’s motion to suppress, concluding that it is permissible for the police to briefly detain the companion of a suspect, incident to the lawful stop of the suspect, even though the police lack reasonable suspicion to believe the companion has engaged in or is engaging in criminal behavior. The Supreme Court affirmed, holding that the police were authorized to stop and briefly detain Defendant, as a reasonable safety measure, in connection with the lawful detention of the individual he was accompanying because the police reasonable believed that the other individual was armed and dangerous. View "State v. Kelly" on Justia Law

After a jury trial, Defendant was convicted of murder and sentenced to fifty years imprisonment. Defendant appealed, contending that he had been deprived of a fair trial because of improper statements made by the prosecutor during trial and in closing argument. The Appellate Court affirmed the judgment of conviction, concluding that only certain statements by the prosecutor were improper, and Defendant was not deprived of a fair trial as a result. Defendant and the State separately appealed. The Supreme Court affirmed, holding (1) the State’s appeal must be dismissed because the State was not aggrieved by the judgment of the Appellate Court; and (2) Defendant was not deprived of a fair trial. View "State v. Albino" on Justia Law

After a jury trial, Defendant was convicted of various criminal offenses in connection with the shooting of Johnnie Jones. On appeal, Defendant argued that the victim’s conduct in identifying Defendant as the perpetrator was unduly suggestive in violation of his due process rights. At issue before the Supreme Court was whether the due process clauses of the Connecticut constitution provide protection against allegedly unduly suggestive eyewitness identification procedures undertaken by a private actor, even in the absence of any improper state action. The Supreme Court affirmed the convictions, holding (1) any eyewitness identifications that are not tainted by any unduly suggestive state action do not implicate due process principles unless the identification was so unreliable that its admission deprived the defendant of his right to a fair trial; and (2) because Defendant’s claim in this case that the victim’s identification of him as the perpetrator should be suppressed on the ground that it was unduly suggestive did not implicate the state constitution, and because Defendant did not raise the claim at trial, it was not reviewable. View "State v. Johnson" on Justia Law

Under the apparent authority doctrine recognized by the United States Supreme Court, a warrantless entry is valid when based upon the consent of a third party whom the police, at the time of the entry, reasonably believe to possess common authority over the premises, but who in fact does not have such authority. The trial court in this case denied Defendant’s motion to suppress evidence obtained after law enforcement’s warrantless entry of Defendant’s apartment based on the apparent authority doctrine. After a jury trial, Defendant was convicted. On appeal, Defendant contended that although the apparent authority doctrine is recognized as an exception to the warrant requirement under the federal constitution, it is inconsistent with Conn. Const. art. I, 7. The Appellate Court concluded that application of the doctrine does not offend the right of Connecticut citizens to be free from unreasonable searches under article first, section 7. The Supreme Court affirmed, holding that the Appellate Court’s opinion was a proper statement of the applicable law on this issue. View "State v. Buie" on Justia Law

After a jury trial, Petitioner was convicted of several offenses in connection with an incident involving Petitioner’s estranged girlfriend. Petitioner later filed a second amended petition for a writ of habeas corpus, claiming that his trial counsel provided ineffective assistance. Specifically, Petitioner alleged that his counsel’s criminal prosecution shortly before Petitioner’s criminal trial constituted a conflict of interest. The habeas court denied Petitioner’s petition. The appellate court affirmed, concluding that Petitioner’s claim failed on the merits. At issue before the Supreme Court was whether there was a constitutionally impermissible risk that a jury would attribute the conduct of Petitioner’s trial counsel to Petitioner when his counsel had been acquitted of a dissimilar crime in the same judicial district in which Petitioner faced criminal prosecution. The Supreme Court affirmed, holding that Petitioner failed to demonstrate an actual conflict of interest that adversely affected his trial counsel’s performance. View "Rodriguez v. Comm'r of Corr." 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