Justia Civil Rights Opinion Summaries
Articles Posted in Connecticut Supreme Court
State v. Haughwout
The Supreme Court affirmed in part and reversed in part Defendant's convictions on charges arising from two separate incidents between him and officers of the Clinton Police Department in July 2015, holding that Defendant's conviction in the case relating to events of July 19, 2015 must be reversed and the conviction in the case relating to the events of July 22, 2015 is reversed with respect to one assault count.On appeal, Defendant argued (1) evidence of certain events during the first incident should have been suppressed because those events were the result of an unconstitutional investigatory detention, and (2) his convictions of two counts of assault of public safety personnel related to the second incident was infirm because the evidence was insufficient and the trial court erred in instructing the jury. The Supreme Court reversed in part, holding (1) the trial court erred in denying Defendant's motion to suppress; and (2) a new trial was required with respect to one of the assault charges due to instructional error. View "State v. Haughwout" on Justia Law
State v. Griffin
The Supreme Court affirmed the judgment of the trial court convicting Defendant of murder, criminal attempt to commit robbery in the first degree, conspiracy to commit robbery in the first degree, and criminal possession of a firearm, holding that the trial court did not err in denying Defendant's motions to suppress.In his suppression motions, Defendant sought to suppress (1) the firearm and related evidence seized from his residence, which evidence he argued was discovered as a result of an unlawful search, and (2) the incriminating statements he made during an interrogation at the police station, claiming the statements were made involuntarily. The Supreme Court affirmed the denial of Defendant's motions to suppress, holding (1) the trial court properly Defendant's motion to suppress the evidence obtained during the search of his residence; and (2) Defendant's statements were voluntary, and the trial court properly admitted them into evidence at trial. View "State v. Griffin" on Justia Law
State v. Silva
The Supreme Court affirmed the judgment of the trial court convicting Defendant of one count of murder with special circumstances and imposing a mandatory sentence under Conn. Gen. Stat. 53a-35a(1)(B) of life imprisonment without the possibility of release, holding that there was no error in the proceedings below.Specifically, the Supreme Court held that the trial court (1) correctly instructed the jury on the "in the course of a single transaction" element of murder with special circumstances; (2) did not commit plain error by failing to provide the jury, sua sponte, with a special credibility instruction with respect to one of the State’s witnesses, who Defendant claimed was the actual perpetrator of the murders; and (3) did not violate Defendant's state and federal constitutional rights to counsel and to present a defense by precluding defense counsel from making a certain argument in closing argument. View "State v. Silva" on Justia Law
State v. Watson
The Supreme Court affirmed the judgment of the appellate court affirming Defendant's convictions of three distinct crimes in connection with his attack on a single victim over the course of an eight-hour period on a single day, holding that there was no error.Defendant was convicted of assault in the third degree, unlawful restraint in the first degree, and strangulation in the second degree. On appeal, Defendant argued that his constitutional right to a jury trial was violated when the trial court, rather than the jury, determined that the charges of assault and unlawful restraint were not "upon the same incident" as that giving rise to the charge of strangulation. The appellate court affirmed. The Supreme Court affirmed, holding that the trial court's determination at sentencing that the offenses of strangulation, assault, and unlawful restraint were not "upon the same incident" did not implicate the constitutional principles underlying Apprendi v. New Jersey, 530 U.S. 490 (2000), or double jeopardy concerns. View "State v. Watson" on Justia Law
State v. Pompei
The Supreme Court affirmed Defendant's conviction of two counts of interfering with an officer, in violation of Conn. Gen. Stat. 53a-167a(a), holding that there was no error in the proceedings below.At issue on appeal was whether the trial court erred in denying Defendant's pretrial motion to suppress on the grounds that he was seized in violation of the Fourth Amendment when a marked police cruiser blocked the egress of his vehicle, which was parked with its engine running and Defendant asleep in the driver's seat. The Supreme Court affirmed, holding that no violation of the Fourth Amendment occurred because the responding officer was checking on Defendant's well-being pursuant to the officer's community caretaking function and was not engaged in an investigatory stop involving criminal activity. View "State v. Pompei" on Justia Law
State v. Komisarjevsky
The Supreme Court affirmed the judgment of the trial court convicting Defendant of six counts of capital felony, among other crimes, holding that Connecticut's individual voir dire process protected Defendant's right to a fair trial by assessing and mitigating the prejudicial effects of pretrial publicity about this notorious case.The State charged Defendant with six counts of capital felony, three counts of murder, four counts of kidnapping, and other crimes. Following extensive pretrial motions practice, Defendant's case was tried to a jury, which returned a guilty verdict on all counts. The trial court subsequently sentenced Defendant to six consecutive death sentences. On appeal, Defendant claimed, among other allegations of error, that the trial court improperly denied his motion to change the venue of his trial given the effects of prejudicial pretrial publicity. The Supreme Court affirmed, holding (1) the pretrial publicity did not result in actual jury prejudice that deprived Defendant of a fair trial; and (2) Defendant was not entitled to relief on his remaining allegations of error. View "State v. Komisarjevsky" on Justia Law
State v. Davis
The Supreme Court remanded this case to the trial court for further proceedings, holding that the trial court erred by failing to inquire into defense counsel's alleged conflict of interest.Defendant was convicted of one count of murder and sentenced to fifty years of imprisonment. On appeal, Defendant argued that his federal constitutional right to the effective assistance of counsel was violated during trial when the court denied his motions to dismiss his counsel without adequately inquiring into certain bases for his motions and when the court failed to conduct any inquiry into defense counsel's alleged conflict of interest. The Supreme Court affirmed, holding that the trial court inadequately inquired into the bases for Defendant's motions to dismiss defense counsel. View "State v. Davis" on Justia Law
Moore v. Commissioner of Correction
The Supreme Court affirmed the judgment of the appellate court dismissing Petitioner's appeal from the judgment of the habeas court denying Petitioner's petition for a writ of habeas corpus, holding that Petitioner could not prevail on his claim of ineffective assistance of trial counsel.Petitioner was convicted of robbery in the first degree. Later, Petitioner filed a petition for a writ of habeas corpus, asserting that he had received ineffective assistance of counsel during plea negotiations prior to his trial. The appellate court dismissed the petition. The Supreme Court affirmed, holding that Petitioner failed to meet his burden of proving that his attorney did not adequately advise him of his maximum sentencing exposure if convicted of the lesser included offense of robbery in the third degree. View "Moore v. Commissioner of Correction" on Justia Law
State v. Gonzalez
The Supreme Court affirmed the decision of the appellate court affirming the judgment of the trial court convicting Defendant of three counts of sexual assault in the first degree and other crimes, holding that neither the structure nor the content of the prosecutor's closing argument deprived Defendant of his constitutional rights.On appeal, Defendant argued that the prosecutor deprived him of his constitutional rights to present a closing argument and to a fair trial by reserving her analysis of certain evidence for the rebuttal portion of closing argument and by mischaracterizing other evidence during rebuttal. The appellate court affirmed. The Supreme Court affirmed, holding that Defendant's claims of prosecutorial impropriety failed. View "State v. Gonzalez" on Justia Law
Ross v. Commissioner of Correction
The Supreme Court affirmed the judgment of the appellate court, which affirmed the judgment of the habeas court denying Petitioner's amended petition for a writ of habeas corpus, holding that Petitioner failed to demonstrate that he was prejudiced by his trial counsel's failure to object to the prosecutor's improper comments during closing argument at Petitioner's criminal trial.Petitioner was convicted of murder. On appeal, the appellate court concluded that at least one of the prosecutor's comments during closing argument violated Petitioner's constitutional right to a fair trial but that Petitioner had not been prejudiced by the improper remarks. The Supreme Court affirmed, holding that the failure to Petitioner's criminal trial counsel to object to the prosecutor's improper remarks did not undermine the Court's confidence in the verdict. View "Ross v. Commissioner of Correction" on Justia Law