Justia Constitutional Law Opinion Summaries

Articles Posted in Connecticut Supreme Court
by
The Supreme Court affirmed the judgments of the trial court terminating Parents' parental rights pursuant to Conn. Gen. Stat. 17a-112(j), holding that Parents were not entitled to relief on their three unpreserved constitutional claims relating to the virtual nature of the termination of parental rights trial.On appeal, Parents argued (1) the trial court violated their rights under Conn. Const. art. I, 10 and art. V, 1 by conducting the termination trial virtually rather than in person; (2) the trial court violated their constitutional right to due process by denying them the right to physically confront and cross-examine the witnesses against them at the virtual trial; and (3) the constitutional rights were violated when the trial court did not provide them with their own exclusive devices and internet connection to participate both visually and by audio in the trial. The Supreme Court affirmed, holding that Parents were not entitled to relief on their unpreserved claims of error. View "In re Vada V." on Justia Law

by
The Supreme Court reversed the judgment of the appellate court insofar as that court reversed the trial court's rulings on Parents' motions for posttermination visitation and affirmed the judgment insofar as the appellate court upheld the trial court's termination of Parent's parental rights, holding that the trial court correctly articulated the proper standard.The appellate court reversed the trial court's denial of Parents' posttermination visitation motions on the ground that the trial court applied an incorrect legal standard in considering these motions. The Supreme Court reversed in part, holding that the appellate court (1) correctly concluded that Mother failed to establish that there exists a fundamental right under the Connecticut Constitution to an in-person termination of parental rights trial; and (2) improperly reversed the trial court's rulings on Parents' motions for failing to comply with the standard set forth in In re Ava W., 248 A.3d 675 (Conn. 2020), for deciding motions for posttermination visitation. View "In re Annessa J." on Justia Law

by
The Supreme Court affirmed the judgment of the appellate court affirming the trial court's judgment convicting Defendant of one count of murder, holding that Defendant was not entitled to relief on any of his allegations on appeal.Specifically, the Supreme Court held that the appellate court correctly concluded that the trial court (1) did not violate Defendant's Sixth Amendment right to present a defense by excluding from evidence a statement purportedly made by an unknown female bystander and an autopsy toxicology report; (2) did not violate Defendant's right to due process by declining to give a jury instruction on self-defense; and (3) did not abuse its discretion by declining to sanction the state for its late disclosure of the murder weapon and related expert reports by excluding this evidence or dismissing the murder charge. The Court further cautioned the State regarding the late disclosure of evidence. View "State v. Hargett" on Justia Law

by
The Supreme Court affirmed the judgment of the habeas court granting Petitioner's petition for writ of habeas corpus after determining that Petitioner had suffered prejudice as a result of the ineffective assistance of his trial counsel, holding that there was no error.In granting habeas relief, the habeas court determined that Petitioner's trial counsel failed to provide Petitioner with professional advise and assistance during pretrial plea negotiations and that Petitioner would have accepted the trial court's pretrial plea offer but for the ineffective assistance of Petitioner's trial counsel. The Supreme Court affirmed, holding that the habeas court did not err in concluding that Petitioner had fulfilled his burden of establishing prejudice. View "Barlow v. Commissioner of Correction" on Justia Law

by
The Supreme Court reversed the judgment of the trial court accepting Defendant's plea of nolo contendere to robbery in the first degree and assault in the first degree and sentencing Defendant to an aggregate sentence of ten years' imprisonment, holding that a John Doe arrest warrant was invalid and could not commence prosecution for purposes of satisfying the statute of limitations.On appeal, Defendant argued that the John Doe arrest warrant that identified the suspect on the basis of a general physical description and several mixed partial DNA profiles to which the suspect may not have been a contributor and that did not state the probability that a random person would match any of the profiles did not satisfy the particularity requirement of the Fourth Amendment for purposes of commencing a prosecution within the applicable statute of limitations. The Supreme Court agreed, holding that, to satisfy the Fourth Amendment's particularity requirement, the affidavit accompanying a John Doe DNA arrest warrant application must contain information assuring the judicial authority issuing the warrant that the DNA profile identifies the person responsible for the crime on the basis of his or her unique DNA profile and should include information as to the statistical rarity of that DNA profile. View "State v. Police" on Justia Law

by
The Supreme Court exercised its supervisory authority to require that a trial court either canvass the defendant or, in certain circumstances, inquire of defense counsel directly to determine whether the defendant was properly advised regarding the waiver of his right to testify.Defendant was convicted of one count of sexual assault in the first degree following a jury trial at which he did not testify. On appeal, Defendant argued that defense counsel's representation that Defendant had waived his right to testify was insufficient to constitute a waiver of that right. The Supreme Court affirmed, holding (1) the constitution does not require that a defendant personally assert the waiver of his constitutional right to testify on the record; but (2) an on-the-record canvass of a defendant is the best practice to ensure that the defendant's waiver of his right to testify is made knowingly, intelligently and voluntarily. View "State v. Morel-Vargas" on Justia Law

by
The Supreme Court affirmed the judgment of the trial court convicting Defendant of murder and carrying a pistol without a permit, holding that there was no error or abuse of discretion in the proceedings below.On appeal, Defendant argued that the trial court abused its discretion in excluding evidence of an assault of one of the state's witnesses and that the trial court erred by preventing him from impeaching another witness with evidence of previous criminal offenses. The Supreme Court affirmed, holding (1) the trial court's exclusion of evidence related to the assault did not violate Defendant's constitutional rights to present a defense and to confront the witnesses against him; and (2) the trial court did not violate Defendant's constitutional right to confrontation or the rules of evidence by preventing him from impeaching the witness with evidence of certain prior criminal convictions. View "State v. Torres" on Justia Law

by
The Supreme Court reversed the judgment of the appellate court affirming the decision of the habeas court dismissing Petitioner's petition for a writ of habeas corpus as barred by a procedural default, holding that Petitioner's pleadings met the standard necessary to survive a motion to dismiss.Petitioner was found guilty by a jury of sexual assault in the first degree and risk of injury to a child. In the instant case, Petitioner sought a second writ of habeas corpus, alleging that he suffered from severe intellectual disabilities and mental health afflictions at the time of trial and that he was denied due process because he was incompetent to be prosecuted and to stand trial. The habeas court dismissed the petition on the ground that Petitioner's due process claims were procedurally defaulted. The appellate court affirmed. The Supreme Court reversed, holding (1) Petitioner was not precluded from raising a freestanding competency claim; and (2) the habeas court erred in finding that Petitioner failed to allege sufficient prejudice to survive a motion to dismiss. View "Saunders v. Commissioner of Correction" on Justia Law

by
The Supreme Court affirmed the judgment of the appellate court affirming Defendant's conviction of murder, holding that the appellate court did not err.On appeal, the appellate court concluded that the trial court had not abused its discretion in joining Defendant's case with the codefendant's case and that Defendant's right to confrontation was not violated when the trial court allowed a state's firearms examiner to testify about the findings of a second firearms examiner. The Supreme Court affirmed, holding (1) the appellate court did not err in determining that the trial court's joinder of Defendant's and his codefendant's cases was proper; (2) the admission of CSLI information into evidence was not error; and (3) the appellate court did not err by not determining that Defendant's right to confrontation was not violated by the challenged testimony, but the violation was harmless beyond a reasonable doubt. View "State v. Tyus" on Justia Law

by
The Supreme Court affirmed the judgment of the habeas court denying in part Petitioner's petition for a writ of habeas corpus, holding that the habeas court correctly concluded that Petitioner did not demonstrate that he had suffered prejudice from the ineffective assistance of his trial counsel.Petitioner, a citizen of Jamaica who held a valid green card, pleaded guilty, pursuant to the Alford doctrine, to risk of injury to a child and strangulation in the third degree. The federal government subsequently initiated removal proceedings against Petitioner based, in part, on his conviction of risk of injury to a child. Petitioner filed a petition for a writ of habeas corpus, alleging ineffective assistance of counsel alleging that he would have gone to trial had his trial counsel not performed deficiently. The habeas court denied the petition as to the claim at issue in this appeal. The Supreme Court affirmed, holding that Petitioner did not meet his burden of establishing that there was a reasonable probability that he would have rejected the plea offer and proceeded to trial. View "Grant v. Commissioner of Correction" on Justia Law