Justia Civil Rights Opinion Summaries

Defendant Miguel C. was convicted, after a jury trial, of three counts of sexual assault in the first degree and three counts of risk of injury to a child. Defendant appealed, claiming that he was entitled to a new trial because the complainant improperly testified about an alleged confession by Defendant to his wife. The Supreme Court reversed the judgment of conviction and ordered a new trial, holding (1) the contested portion of the complainant's testimony was improperly admitted, as its probative value was outweighed by the prejudicial effect; and (2) the verdict was substantially affected by that testimony, and therefore, the error was harmful.

Defendant was convicted of assault of public safety personnel. The appellate court reversed the conviction on the ground that the trial court had compelled Defendant to wear identifiable prison clothing at his jury trial in contravention of his constitutional right to a fair trial. The Supreme Court affirmed the judgment of the appellate court on the alternative ground that reversing Defendant's conviction was warranted in the exercise of the Court's inherent supervisory authority over the administration of justice, holding (1) in the absence of a defendant's voluntary decision to stand trial before a jury in prison clothing, a court must ensure that the defendant has civilian clothing to wear at trial, and its failure to comply with this requirement will result in reversal of the defendant's conviction; and (2) the trial court in this case erred in compelling Defendant to stand trial in identifiable prison clothing.

Defendant Anthony Thompson was convicted of one count of murder and two counts of assault in the first degree. The Supreme Court affirmed, holding (1) the trial court applied the proper standard in admitting into evidence a statement to the police and a signed photographic array by a deceased eyewitness identifying Defendant as the shooter; (2) there was sufficient evidence to support the trial court's finding that Defendant had caused the death of the witness; and (3) even if the trial court improperly admitted evidence relating to the circumstances surrounding the death of the witness to show consciousness of guilt, the impropriety was harmless.

In this case a jury found that Marc Pascual hired Defendant Eduardo Santiago to murder the victim and that Defendant acted in concert with Matthew Tyrell to break into the victim's home and fatally shoot him. The jury then returned a verdict finding Defendant guilty of all the charged offenses in the ten count information, including capital felony. The trial court sentenced Defendant to death by lethal injection. The Supreme Court (1) affirmed the underlying judgment of conviction; but (2) reversed the judgment insofar as it imposed a sentence of death, holding that the trial court did not err when it reviewed the department of children and families' file in camera, but the scope of its review failed to disclose significant and relevant mitigating evidence, requiring that Defendant receive a new penalty phase hearing. Remanded to the trial court for a new penalty phase hearing, following a new in camera review of the department's files and disclosure of evidence material to Defendant's case in mitigation.

Following a jury trial, Defendant Daniel Golodner was convicted of two counts of interfering with an officer and two counts of reckless endangerment in the second degree in connection with a dispute over a neighbor's attempt to have their common property boundary surveyed. The Supreme Court affirmed the judgment in part and reversed the judgment in part with respect to the conviction on the second charge of reckless endangerment, holding that the trial court improperly denied Defendant's motion to dismiss the second charge of reckless endangerment for violation of the statute of limitations. Remanded with direction to render judgment of acquittal on that charge and for resentencing.

After a jury trial, Defendant Francisco Pascual was convicted of several charges relating to his alleged attempt to sexually assault a twelve-year-old girl from El Salvador after the victim illegally crossed the border from Mexico into the United States. Defendant appealed, claiming that the trial court improperly (1) admitted hearsay evidence that, several days before the charged events, the victim was told about a threat made by an unidentified third party, and (2) instructed the jury that the threat evidence was admitted to show that the victim reasonably feared Defendant in order to prove sexual assault and kidnapping charges. The Supreme Court affirmed, holding that, even if the trial court improperly admitted the evidence and gave improper instructions to the jury, Defendant was not entitled to a new trial because the purported improprieties were not harmful.

Following a jury trial, Defendant Kenneth John Otto, Sr. was convicted of murder and tampering with evidence. Defendant appealed. The Supreme Court affirmed the judgment of the trial court, holding (1) there was sufficient evidence to prove the element of specific intent necessary to support the murder conviction; and (2) in closing arguments the prosecutor did not improperly invite the jury to apply an incorrect legal standard or improperly suggest that the jury could find Defendant guilty of murder even if it did not find that he had the requisite intent to kill, simply to punish him for destroying evidence.

Defendant Torrence Benton was convicted on charges of carrying a pistol without a permit and criminal possession of a pistol or revolver. Defendant appealed, claiming that the trial court improperly denied his motion to suppress evidence obtained in a search incident to his arrest. Specifically, Defendant contended that police seized him prior to his arrest without reasonable and articulable suspicion that he was engaged in criminal activity. The Supreme Court affirmed, holding that the totality of the circumstances in this case furnished sufficient reasonable and articulable suspicion that Defendant was engaged in criminal activity to justify the police stopping him.

Plaintiff G. Berry Schumann, a twelve year employee of Defendant, Dianon Systems, brought a complaint against Defendant alleging a violation of Conn. Gen. Stat. 31-51q and common-law wrongful termination of employment for an adverse employment action Defendant took against Plaintiff in response to speech made during the course of Plaintiff's job duties. The trial court found in favor of Plaintiff. At issue on appeal was whether the rule in Garcetti v. Ceballos, which states that public employees who make statements pursuant to their official duties are not insulated from employer discipline for First Amendment purposes, is applicable in an action brought against a private employer pursuant to section 31-51q. The Supreme Court reversed, holding (1) the rule in Garcetti applies to claims under section 31-51q grounded in the First Amendment that are brought against private employers; and (2) Plaintiff's speech was in the course of his employment duties for Defendant and, therefore, was not entitled to First Amendment protection under Garcetti. Remanded with direction to render judgment for Defendant on the claim under section 31-51q and for a new trial limited to Plaintiff's common-law wrongful termination claim.

Plaintiff Carmen Perez-Dickson brought this action claiming that Defendants, the city board of education, the former assistant superintendent of the school district, and the former acting superintendent of the school district, disciplined her for exercising her right to free speech protected by the state and federal Constitutions in violation of Conn. Gen. Stat. 31-51q and 17a-101e, discriminated against her on the basis of her race, and intentionally caused her severe emotional distress. The jury returned a verdict in favor of Plaintiff on all counts. The Supreme Court reversed, holding (1) Defendants did not violate section 31-51q because any relevant speech by Plaintiff had been pursuant to her official job duties and such speech is not protected by the First Amendment; (2) Plaintiff failed to prove her claim of racial discrimination; and (3) Plaintiff failed to prove that Defendants had intentionally inflicted severe emotional distress on her. Remanded with direction to render judgment for Defendants.