Justia Constitutional Law Opinion Summaries

After a joint jury trial with his codefendant, Petitioner was convicted of ten charges arising from a murder and robbery. The Appellate Court affirmed. Petitioner thereafter filed a petition for a writ of habeas corpus, claiming that his trial counsel provided ineffective assistance by failing to conduct an adequate pretrial investigation and failing adequately to present a defense at trial. The habeas court granted the petition and ordered that Petitioner’s conviction be set aside, concluding that counsel’s failure to obtain information regarding a stolen cell phone before trial was deficient performance and that the deficient performance prejudiced Petitioner’s defense. The Supreme Court reversed, holding that counsel’s failure to investigate the issue of the stolen cell phone evidence was not prejudicial under Stickland v. Washington. View "Horn v. Comm’r of Corr." on Justia Law

Lopez-Gay, with Sabato and others, was at a Danbury nightclub, when her cell phone was stolen. She used an application on her computer to track its location to the Danbury Mall. Danbury police were unable to find it. That day, Sabato asked Mason to drive him to the mall and sold Mason the cell phone. Because the phone was password-protected, Mason was unable to use it. Mason took the phone to a friend, in Newtown, who worked servicing cell phones. Meanwhile, Lopez-Gay again used the tracking application and called the Newtown Police. Mason relinquished the phone when confronted, then sent Sabato a text message telling him that he was at the police station. Sabato replied, telling Mason not to write a statement. After discovering that Mason had made a statement, Sabato sent Mason threatening Facebook messages. Sabato was convicted of attempt to interfere with an officer G.S. 53a-167a (a)1; 53a- 49 (a) (2), and intimidating a witness, G.S. 53a-151a (a) (1). The Connecticut Supreme Court affirmed the intimidation conviction, but reversed the conviction of attempt to interfere with an officer. Fighting words are the only form of speech proscribed by Section 53a-167a, and Sabatot’s text message contained no such language. The state was precluded from arguing that it constituted a true threat, having never pursued such a theory at trial. Merely asking Mason not to give a statement was constitutionally protected and outside the purview of the statute. View "State v. Sabato" on Justia Law

The petitioner was convicted by a three-judge​ panel and sentenced to death for the murder of a police officer in December, 1992. The Connecticut Supreme Court affirmed the conviction and sentence in 2003 and the U.S. Supreme Court denied certiorari. The petitioner filed a petition for a writ of habeas corpus, claiming that trial and appellate counsel rendered constitutionally ineffective assistance by failing to raise or sufficiently present several claims. The habeas court rejected each claim. On appeal, the petitioner raised 13 separate issues, most concerning his death sentence, and a few related to his capital felony conviction. The Connecticut Supreme Court reversed his death sentence, citing its decisions in State v. Santiago (2015) and State v. Peeler (2016). The court rejected claims that the criminal trial court lacked subject matter jurisdiction because the state used a short-form information to charge him; that trial counsel rendered constitutionally ineffective assistance with respect to testimony by an individual who was with petitioner at the time of the murder and who, he alleged, was treated with leniency; and that international law precluded his conviction for a capital felony. View "Reynolds v. Comm'r of Corr." on Justia Law

After a jury trial, Defendant was convicted of two counts of assault in the second degree. Defendant appealed, arguing that the trial court’s denial of his motion to suppress his statements to the police made during his booking violated his Fifth Amendment rights and that he was subjected to custodial interrogation without Miranda warnings at the crime scene. The Appellate Court affirmed, holding that the public safety exception to Miranda, as articulated in New York v. Quarles, applied. The Supreme Court affirmed, holding that, based on the circumstances of this case, the public safety exception applied. View "State v. Smith" on Justia Law

After a jury trial, Defendant was convicted of both intentional and reckless assault in the first degree. Defendant filed a motion for a new trial, arguing that the convictions were legally inconsistent. The trial court denied the motion. The Appellate Court reversed, concluding that Defendant’s convictions for intentional and reckless assault were legally inconsistent. The Supreme Court reversed, holding (1) Defendant’s convictions were not legally inconsistent under the State’s argument that the assault occurred in two reckless and intentional phases, respectively; and (2) Defendant had sufficient notice that he could be convicted of both reckless and intentional assault, and therefore, the manner in which Defendant was convicted satisfied the requirements of due process. View "State v. King" on Justia Law

Defendant entered a conditional plea of nolo contendere to possession of a controlled substance with intent to sell. Prior to entering the plea, Defendant moved to suppress evidence seized from his vehicle, claiming that the police did not possess a reasonable and articulable suspicion that he was engaged in or about to engage in criminal activity. On appeal, Defendant challenged the the trial court’s denial of his motion to suppress. The Appellate Court reversed, concluding that the trial court’s determination that the police possessed a reasonable and articulable suspicion that criminal activity was afoot when they detained Defendant was incorrect. The Supreme Court reversed, holding that, under the totality of the circumstances, the police possessed a reasonable and articulable suspicion to detain Defendant outside a known drug location where Defendant had previously acted in a manner consistent with drug activity. View "State v. Peterson" on Justia Law

Defendant pleaded guilty to harassment in the second degree and criminal trespass in the first degree and was sentenced to one year incarceration, execution suspended, and two years of probation. Defendant was later charged with violating the conditions of his probation. After a hearing, the trial court found that Defendant violated the conditions of his probation, continued Defendant’s probation, and added new conditions. The Supreme Court affirmed, holding (1) the trial court properly admitted evidence that Defendant argued should have been suppressed; (2) the evidence was sufficient to demonstrate that Defendant violated the terms of his probation; (3) the trial court did not err in admitting certain hearsay evidence; and (4) Defendant waived his Second Amendment right to possess firearms when he agreed to the condition of his probation barring him from possessing firearms. View "State v. Maietta" on Justia Law

After a jury trial, Defendant was convicted in two consolidated cases of attempted murder, two counts of risk of injury to a child, and murder. The Supreme Court reversed, concluding that the trial court improperly granted the State’s motion to disqualify his chosen attorney, Gary Mastronardi, and that the improper disqualification was structural error requiring a new trial. On remand, Defendant filed a motion asking the State to fund Mastronardi’s private fee or, alternatively, to dismiss the charges against him on the grounds that he was now indigent and tat Mastronardi would not represent him at the new trial at the rate paid to assigned counsel by the Division of Public Defender Services. The trial court denied Defendant’s motion, concluding that the Supreme Court’s decision Peeler I did not require it. After a second jury trial, Defendant was found guilty on all counts. The Supreme Court affirmed, holding that the trial court did not violate Defendant’s right to counsel of choice at his new trial by denying his funding motion. View "State v. Peeler" on Justia Law

After a jury trial, Defendant was convicted of crimes committing during a string of armed robberies in the cities of Stamford and Norwalk and the town of Greenwich. Defendant appealed, arguing (1) his constitutional right to counsel was violated when the trial court admitted incriminating statements he made regarding the Norwalk and Greenwich robberies while he was represented by counsel in the case involving the Stamford robbery; and (2) the trial court violated his constitutional right to confrontation by restricting defense counsel’s cross-examination of a key prosecution witness. The Supreme Court affirmed, holding that the trial court’s admission of the incriminating statements and its restrictions on counsel’s cross-examination of the witness did not violate Defendant’s Sixth Amendment rights or constitute an abuse of discretion. View "State v. Leconte" on Justia Law

In 2013, the legislature amended the statutes governing Connecticut’s public land records system to create a two-tiered system in which a nominee of a mortgagee operating a national electronic database to track residential mortgage loans must pay substantially more in recording fees than do other mortgagees. Mortgage Electronic Registration Systems, Inc. and MERSCORP Holdings, Inc. (collectively, Plaintiffs), the only entities currently required to pay the increased recording fees, brought this action against Defendants - the governor, attorney general, treasurer, state librarian, and state public records administrator - seeking injunctive relief and a judgment declaring that this two-tiered fee structure violates various provisions of the federal and state constitutions. The trial court granted summary judgment in favor of Defendants. The Supreme Court affirmed, holding that the fees do not violate the equal protection guarantees of the state and federal constitutions or the dormant commerce clause of the federal constitution. View "MERSCORP Holdings, Inc. v. Malloy" on Justia Law