Justia Civil Rights Opinion Summaries

Following a jury trial, Defendant Sheri Paige, then an attorney, was convicted of nine charges relating to the theft of assets from an elderly client, including one count of perjury. With respect to the perjury instruction, although Defendant had submitted a request to charge the jury that it must decide whether a particular statement at issue was material and the State had conceded that it was improper for the trial court to have instructed the jury that the State had proven this element as a matter of law, the appellate court determined that Defendant had waived her right to challenge the instruction that was given. The Supreme Court reversed the judgment in part, holding that the appellate court erred in determining that Defendant had waived her right to challenge the instruction. Remanded for a new trial on the charge of perjury.

After a jury trial, Defendant John Jackson was convicted of murder. The Supreme Court affirmed the judgment of conviction, holding that the trial court did not err in denying (1) Defendant's motion to suppress certain evidence seized by the police without a search warrant, as Defendant had abandoned his expectation of privacy with respect to the seized items; (2) Defendant's motion to preclude certain evidence that the state had disclosed in an untimely manner, as Defendant established neither that there were exceptional circumstances requiring preclusion nor that he would have been prejudiced by the late disclosure; (3) Defendant's motion to suppress certain statements that he gave to the police, as Defendant was not in custody when he made the statements and the statements were voluntary; and (4) denying Defendant's request to give a jury instruction on third party culpability, as the evidence did not support the instruction.

The State filed an application for an arrest warrant for Defendant, alleging a charge of kidnapping in the first degree for the purpose of committing a sexual assault. The trial court ordered that the affidavit supporting the arrest warrant, which recounted statements of the victim and other individuals regarding the incident, be sealed for fourteen days. The victim requested that the affidavit remain sealed indefinitely, citing her right to be treated with fairness and respect throughout the criminal justice process under the state's victims rights amendment. The trial court denied the victim's motion. The Supreme Court dismissed the victim's appeal without reaching its merits, holding that the victim lacked standing to pursue the appeal, as nothing in the victims rights amendment itself or in subsequently enacted legislation explicitly makes victims parties to criminal prosecutions or otherwise affords them rights to appeal.

In the involuntary conservatorship action underlying this case, Daniel Gross was placed in the locked ward of Grove Manor Nursing Home. Jonathan Newman was appointed by the probate court to represent Gross in the action, and Kathleen Donovan was appointed as conservator. The superior court granted Gross's petition for writ of habeas corpus, finding that the conservatorship was void ab initio. Gross subsequently brought a complaint in U.S. District Court, asserting state and federal civil rights claims. The court dismissed it as to all defendants, finding, in relevant part, that Donovan, Newman, and Grove Manor were entitled to immunity because they were serving the judicial process. On appeal, the U.S. court of appeals submitted certified questions regarding Connecticut law to the Supreme Court. The Court held (1) absolute quasi-judicial immunity extends to a conservator appointed by the probate court only when the conservator is executing an order of the probate court or the conservator's actions are ratified by the probate court; (2) absolute quasi-judicial immunity does not extend to attorneys appointed to represent respondents in conservatorship proceedings or conservatees; and (3) the function of nursing homes caring for conservatees does not entitle them to quasi-judicial immunity under any circumstances.

Following a jury trial, Defendant Willie Coleman was convicted of murder in connection with the fatal stabbing of his girlfriend. Defendant appealed, contending that the state offered insufficient evidence to prove beyond a reasonable doubt his intent to kill the victim, that the trial court improperly instructed the jury that it could infer such intent from the number of wounds he had inflicted on her, and that an improper statement by the prosecutor in closing argument deprived him of a fair trial. The Supreme Court affirmed, holding (1) the evidence was sufficient in this case to demonstrate intent; (2) Defendant failed to preserve his claim challenging the jury instructions, and Defendant could not prevail under State v. Golding or the plain error doctrine; and (3) under the circumstances of this case, the prosecutor's remark in closing argument did not deprive Defendant of a fair trial.

A jury found Defendant guilty of four drug-related crimes. The appellate court concluded that there was insufficient evidence to support Defendant's conviction of possession of narcotics with intent to sell within 1500 feet of a school in violation of Conn. Gen. Stat. 21a-278a(b) and possession of drug paraphernalia with intent to use within 1500 feet of a school in violation of Conn. Gen. Stat. 21a-267(c) and remanded the case, directing the trial court to render judgment of not guilty on these charges. The Supreme Court affirmed in part and reversed in part, holding that the appellate court (1) properly held that there was insufficient evidence to support Defendant's conviction under section 21a-278a(b), but (2) improperly held that there was insufficient evidence to support Defendant's conviction under section 21a-267(c). Remanded for a new trial on the charge of possession of drug paraphernalia with the intent to use within 1500 feet of a school.

Defendant Rafael Crespo was convicted of one count of assault in the third degree and two counts of sexual assault in the first degree. Defendant's conviction stemmed from allegations that he had forcibly engaged in sexual intercourse with the victim and physically assaulted her on several occasions during their relationship. The appellate court affirmed. After analyzing the case under State v. Golding the Supreme Court affirmed, holding that the trial court properly excluded impeachment evidence regarding the victim's prior sexual conduct and that the exclusion of this evidence did not clearly violate Defendant's constitutional rights to confrontation and to present a defense.

After a jury trial, Defendant Leotis Payne was convicted of, inter alia, felony murder, robbery in the first degree, and attempt to tamper with a juror. The Supreme Court affirmed, holding (1) the trial court improperly joined for trial the felony murder and jury tampering cases against the Defendant for trial, but the error was harmless; (2) the trial court improperly admitted the testimony of one of the state's witnesses regarding an alleged threat made by Defendant, but the error was harmless; and (3) three statements by the prosecutor during closing and rebuttal arguments were improper, but those improprieties did not deprive Defendant of a fair trial, and therefore, Defendant was not entitled to a new trial due to the prosecutorial improprieties. In affirming the judgments of the trial court, the Court also overruled State v. King and its progeny, which recognized a presumption in favor of joinder in criminal cases.

Defendant Osibisa Hall pleaded guilty to one count of possession of marijuana with intent to sell and two counts of violation of a protective order. Defendant subsequently filed a motion to withdraw his guilty pleas and vacate the judgments of conviction, claiming that the trial court did not fulfill its obligation to address him personally and determine that he understood the immigration consequences of his pleas. The court denied the motion. The appellate court reversed, finding that the trial court failed to comply substantially with Conn. Gen. Stat. 54-1j when it neglected to personally address Defendant regarding the potential immigration consequences of his pleas. The Supreme Court reversed the appellate court, holding (1) substantial compliance with section 54-1j can be established even if the court does not address the defendant personally; and (2) the trial court substantially complied with section 54-1j in the present case.

In an underlying employment dispute, Employee sued Employer for discrimination. After the jury issued a verdict in favor of Defendant, Plaintiff moved for a new trial, alleging that Defendant had engaged in discovery misconduct. The trial court denied Plaintiff's motion. The appellate court affirmed. At issue before the Supreme Court was whether a party seeking a new trial on the basis of alleged knowing and deliberate discovery misconduct must show that the result at a new trial would likely be different. The Supreme Court affirmed, holding that the rule set forth in Varley v. Varley to determine whether a new trial should be granted on the basis of allegations that the judgment was obtained through fraud, as reframed in this decision, applies to motions for a new trial based on the discovery misconduct of the nonmoving party.