Justia Civil Rights Opinion Summaries

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

After a jury trial, Defendant was convicted of several crimes. On appeal, Defendant argued that, during sentencing, the trial court deprived him of his due process rights by improperly considering that Defendant decided to proceed to trial rather than accept a plea bargain. The Appellate Court declined to review Defendant’s sentencing claim on the grounds that it was unpreserved and that Defendant had not properly made an “affirmative request” for review in his main brief under State v. Golding. The Supreme Court reversed in part, holding (1) the requirement that a defendant must “affirmatively request” Golding review in his main brief in order to receive appellate review of unpreserved constitutional claims is overruled, and therefore, the Appellate Court improperly declined to review Defendant’s constitutional claims on that ground; (2) Defendant failed to establish that the trial court penalized him for exercising his right to a jury trial; but (3) the use of the Court’s supervisory authority was warranted to prevent adverse effects on the public’s perception of the inherent fairness of the criminal justice system that may arise when a trial judge could appear to have considered a defendant’s decision to exercise his right to a trial during sentencing. Remanded for a new sentencing hearing. View "State v. Elson" on Justia Law

After a jury trial, Defendant was convicted of murder and other crimes. The Supreme Court (1) reversed the judgment of the trial court as to Defendant’s convictions for the crimes of kidnapping in the second degree and burglary in the first degree, holding that certain evidence relating to the potential impeachment of a key prosecution witness should have been admitted at trial, and that the failure to admit the evidence was not harmless beyond a reasonable doubt as to those counts; and (2) affirmed the trial court in all other respects, holding that the court did not err in its instructions to the jury and that the prosecutor did not engage in misconduct. View "State v. Baltas" on Justia Law

Defendant pled nolo contendere to possession of narcotics with intent to sell to sell by a person who is not drug-dependent, possession of narcotics with intent to sell within 1500 feet of a school, and possession of a weapon in a motor vehicle. Defendant appealed, arguing that the trial court erred in denying his motion to suppress with respect to the narcotics and handgun found in a plastic bag inside the trunk of his vehicle. Specifically, Defendant argued that the search of bags inside the trunk of his vehicle could not be conducted within the automobile exception to the warrant requirement under the Connecticut constitution. The Supreme Court affirmed, holding that the state constitution does not prohibit the warrantless search of a closed container located in the trunk of a vehicle conducted during an otherwise constitutional warrantless search of a vehicle. View "State v. Williams" on Justia Law

Upon responding to a 911 call from a tenant of a rooming house reporting a disturbance involving a gun, police officers entered an unlocked attic space in the house and retrieved marijuana and a gun. After a jury trial, Defendant, who resided in a room on the third floor of the house, was convicted of attempt to commit criminal possession of a firearm, criminal possession of a pistol, and possession of marijuana with intent to distribute. Defendant appealed the denial of his motion to suppress the evidence seized by the police as products of an unlawful search, claiming he had a reasonable expectation of privacy in the attic. The appellate court affirmed, holding that, because of Defendant’s lack of control over the access of others to the attic, Defendant did not have an expectation of privacy in that space that society would recognize as reasonable. The Supreme Court affirmed, holding that appellate court properly resolved the issue by virtue of its well-reasoned decision. View "State v. Pierre" on Justia Law

Upon following up on complaints from Defendant’s neighbor relating to Defendant’s keeping of animals in his residence, a police officer concluded that a “welfare check” was necessary and made a warrantless entry into Defendant’s home. Defendant subsequently entered a plea of nolo contendere to two counts of cruelty to animals. Defendant appealed the trial court’s denial of his motion to suppress on the ground that the warrantless entry was justified under the emergency exception to the warrant requirement. The appellate court reversed, concluding that the evidence did not permit a finding that the police reasonably believed that a warrantless entry was necessary to help a person inside the dwelling who was in immediate need of assistance. The Supreme Court reversed, holding that the trial court properly concluded that, under the totality of the circumstances present in this case, a police officer reasonably would have believed that an emergency existed inside Defendant’s home. View "State v. DeMarco" on Justia Law

After a jury trial, Defendant was found guilty of two drug-related offenses following a police investigation that culminated in the seizure of heroin from defendant’s home pursuant to a search warrant. Defendant appealed, arguing, among other things, that the trial court erred in denying her motion to suppress certain statements because the statements had been obtained when a police officer interrogated her during the execution of the search warrant without first advising her in accordance with Miranda v. Arizona. The appellate court affirmed the convictions, determining that, at the time of the police questioning, Defendant was not in custody for purposes of Miranda, and therefore, Miranda warnings were not required. The Supreme Court reversed, holding (1) Defendant was in custody when she was questioned by the police officer, and, as a result, the police were required to advise her of her rights under Miranda; and (2) the Miranda violation was not harmless beyond a reasonable doubt. View "State v. Mangual" on Justia Law

Defendant was arrested without a warrant and charged with several crimes. Defendant filed a motion to be released without bond because a probable cause finding had not been made within forty-eight hours of his arrest. The trial court denied Defendant's motion. The appellate court upheld the trial court's decision. The Supreme Court affirmed, holding that, under the specific facts of this case, any violation of Defendant's Fourth Amendment rights was de minimis where (1) Defendant was present in the courthouse awaiting arraignment, at which point probable cause findings are typically made, prior to the expiration of the forty-eight hour period; and (2) the trial court found probable case for Defendant's arrest less than two hours after expiration of the forty-eight hour time period. View "State v. Heredia" on Justia Law

Petitioner was charged with various criminal offenses in two informations. After a jury trial, Petitioner was convicted of sexual assault in the second degree, assault in the second and third degrees, and risk of injury to a child. After the convictions were affirmed on appeal, Petitioner filed a petition for a writ of habeas corpus, alleging ineffective assistance of counsel. The habeas court found Petitioner's pretrial counsel had rendered ineffective assistance by failing to provide Petitioner with adequate advice regarding a pretrial plea offer and ordered the trial court to resentence Petitioner in accordance with the sentence proposed in the plea offer. The appellate court affirmed. The Supreme Court reversed, holding that the habeas court improperly circumvented the trial court's discretion to impose an appropriate sentence. Remanded. View "H.P.T. v. Comm'r of Corr." on Justia Law