Justia Civil Rights Opinion Summaries

The Supreme Court affirmed the judgment of the appellate court denying habeas corpus relief after concluding that the doctrine of collateral estoppel barred Petitioner from litigating the issue of whether he was prejudiced he was prejudiced by his counsel's failure to object to the prosecutor's improper comments during closing argument at his criminal trial, holding that Petitioner failed to demonstrate prejudice.Petitioner, who was convicted of murder, filed a petition for a writ of habeas corpus alleging that his criminal trial counsel rendered ineffective assistance by, among other things, failing to object to the prosecutor's improper remarks during closing argument. The court denied the petition, concluding that Petitioner had failed to demonstrate that he had suffered prejudice. The appellate court affirmed on the grounds that Petitioner was collaterally estopped from litigating the issue of prejudice. The Supreme Court affirmed, holding (1) the doctrine of collateral estoppel did not apply; and (2) Petitioner failed to demonstrate prejudice from his counsel's performance. View "Ross v. Commissioner of Correction" on Justia Law

The Supreme Court affirmed the judgment of the trial court revoking Defendant's probation and sentencing him to a two-year term of imprisonment, holding that the trial court did not improperly deny Defendant's motion to dismiss the violation of probation charge.On appeal, Defendant argued that the condition of probation upon which the violation of probation charged was predicated violated his Fourteenth Amendment rights to due process and equal protection as well as the Eighth Amendment prohibition against the imposition of cruel and unusual punishment. The Supreme Court affirmed, holding that Defendant's claims on appeal failed. View "State v. Imperiale" on Justia Law

The Supreme Court affirmed Defendant's conviction of the sexual assault of a twelve-year-old girl and his sentence of thirty-three years, holding that the trial court's enhancement of Defendant's sentence was not fundamentally unfair.On appeal, Defendant argued that, at sentencing, the trial court violated his due process right by penalizing him for refusing to apologize for his criminal misconduct. Specifically, Defendant argued that his sentence contravened his constitutional right against self-incrimination because an apology would necessarily have required him to admit guilt. The Appellate Court affirmed, concluding that there was no evidentiary support for Defendant's contention that the trial court had increased his sentence because of his unwillingness to apologize to the victims. The Supreme Court affirmed, holding that the Appellate Court properly concluded that the trial court did not penalize Defendant for maintaining his innocence at sentencing. View "State v. Angel M." on Justia Law

The Supreme Court reversed the judgment of conviction rendered by the trial court following Defendant's conditional plea of nolo contendere to the charge of possession of a controlled substance with intent to sell, holding that the trial court erred in denying Defendant's motion to suppress.On appeal, Defendant argued that she was illegally detained, along with her codefendant, in a car in the parking lot of a multiunit apartment building because the police lacked either a warrant or a reasonable, articulable suspicion of criminal activity. The Supreme Court reversed, holding that Defendant's detention was not permissible under the exception to the Fourth Amendment's warrant requirement articulated in Michigan v. Summers, 452 U.S. 692, and Bailey v. United States, 568 U.S. 186 (2013) because Defendant was not within the "immediate vicinity" of the apartment to be searched. View "State v. Espino" on Justia Law

The Supreme Court reversed the judgment of conviction rendered by the trial court following Defendant's conditional plea of nolo contendere to the charge of possession of a controlled substance with intent to sell, holding that the trial court erred in denying Defendant's motion to suppress.Defendant sought to suppress evidence seized after his warrantless detention in the parking lot of a multiunit apartment building. The trial court denied the suppression motion. The Supreme Court reversed, holding that Defendant was not an "occupant" within the "immediate vicinity" of the premises subject to a search warrant under the exception to the Fourth Amendment's warrant requirement set forth in Michigan v. Summers, 452 U.S. 692 (1981), and Bailey v. United States, 568 U.S. 186 (2013). View "State v. Rolon" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of two counts of sexual assault in the first degree and one count of criminal attempt to commit sexual assault in the first degree, holding that there was no error.Specifically, the Supreme Court held (1) the trial court did not violate Defendant's right to confrontation by allowing testimony about the results of a DNA identification analysis without requiring testimony from the individual who generated the DNA profiles; (2) Defendant's claim that his due process rights were violated by the introduction of DNA identification evidence that was allegedly unreliable failed under the third prong of State v. Golding, 567 A.2d 823 (Conn. 1989); and (3) there was sufficient evidence to establish Defendant's guilt beyond a reasonable doubt. View "State v. Rodriguez" on Justia Law

The Supreme Court reversed the judgment of the Appellate Court concluding that Defendant's conviction of breach of the peace in the second degree must be reversed because the First Amendment barred his prosecution for the statements at issue, holding that Defendant's remarks were unprotected fighting words, and therefore, his conviction did not violate the First Amendment.At issue were Defendant's "vulgar and racially charged" remarks that included utterances of the words "fucking niggers" directed at an African-American parking enforcement official following Defendant's receipt of a parking ticket. As a result of this conduct, Defendant was convicted of breach of the peace in the second degree. The Appellate Court reversed, concluding that Defendant's speech was constitutionally protected. The Supreme Court reversed, holding that the Appellate Court erred in concluding that Defendant's language did not constitute fighting words. View "State v. Liebenguth" on Justia Law

The Supreme Court reversed the judgment of the trial court convicting Defendant of several crimes in connection with a murder in the city of Hartford in 2002, and remanded this case for a new trial, holding that Defendant's constitutional right to counsel was violated and that, therefore, he was entitled to a new trial on all counts.On appeal, Defendant argued that the State violated its obligation under Messiah v. United States, 377 U.S. 201 (Conn. 1964), to respect and preserve the invocation of his right to counsel under the Sixth Amendment by using a jailhouse informant deliberately to elicit incriminating statements from Defendant. The Supreme Court agreed and reversed Defendant's convictions, holding that the trial court's denial of Defendant's motion to suppress the informant's testimony was improper and that Defendant was entitled to a new trial. View "State v. Ashby" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the Appellate Court affirming Defendant's conviction of two counts of assault in the first degree as a principal and two counts of assault in the first degree as an accessory, holding that the Appellate Court erred insofar as it affirmed Defendant's assault conviction as to Kenneth Tucker.Defendant's convictions were based on a joint physical assault involving two perpetrators, Defendant and his brother, and two victims, Kenneth Tucker and Luis Rodriguez. On appeal, Defendant argued that his conviction of four assault violated his right to be free from double jeopardy under the federal constitution because he committed only one assault per victim, for a total of two assaults. The Supreme Court reversed the Appellate Court's judgment insofar as it affirmed Defendant's conviction as to Tucker, holding (1) the imposition of multiple punishments on Defendant for Tucker's assault violated the Double Jeopardy Clause; and (2) Defendant's criminal acts involving Rodriguez constituted two distinct courses of conduct for double jeopardy purposes. View "State v. Ruiz-Pacheco" on Justia Law

The Supreme Court reversed the judgment of the Appellate Court affirming the judgment of the habeas court denying Petitioner's second petition for a writ of habeas corpus, holding that Petitioner's federal due process rights were violated when the State knowingly failed to correct the false testimony of two prosecution witnesses when defense counsel was aware of the falsity of the testimony.A jury found Petitioner and his codefendants guilty of murder and conspiracy to commit murder. In his second petition for a writ of habeas corpus Petitioner alleged that his prior habeas counsel provided ineffective assistance in that he failed to raise the claim that the State had violated Petitioner's right to due process by failing to correct the allegedly false testimony of two witnesses at trial. The habeas court denied the petition, and the Appellate Court affirmed. The Supreme Court reversed, holding that, in light of the facts of this case, the fact that counsel was aware of the falsity of the testimony was insufficient to protect Petitioner's due process rights. View "Gomez v. Commissioner of Correction" on Justia Law