Justia Constitutional Law Opinion Summaries

Defendant was found not guilty of certain offenses by reason of mental disease or defect and transferred to a maximum security psychiatric facility. Defendant was charged with new, violent crimes while housed at the facility. The trial court set a monetary bond as a condition of release. Because Defendant was unable to post that bond, he was transferred to the custody of the Commissioner of Correction at a prison while awaiting trial on the new charges. Defendant appealed. The Supreme Court affirmed, holding that the trial court’s imposition of a monetary bond and, after Defendant was unable to post that bond, Defendant’s transfer to the custody of the Commissioner, did not violate Defendant’s constitutional rights to (1) bail, pursuant to the Connecticut Constitution; and (2) procedural due process, pursuant to the Fourteenth Amendment to the United States Constitution. View "State v. Anderson" on Justia Law

After a jury trial, Defendant was convicted of one count of sexual assault in the fourth degree. During trial, in seeking to imply that the complainant had a motive to testify favorably for the State, Defendant sought to question the complainant on recross-examination about the conditions of her participation in a pretrial diversionary program on a felony charge pending against her in an unrelated case. The trial court concluded that the prejudicial effect of the proffered evidence was greater than its probative value. The Appellate Court reversed the conviction, concluding that the trial court violated Defendant’s right to confrontation by precluding Defendant from eliciting such evidence. The Supreme Court reversed, holding that Defendant failed to establish a sufficient nexus between the testimony he sought to obtain and the complainant’s motive to testify favorably for the State to implicate his right to confrontation. View "State v. Benedict" on Justia Law

Defendant’s conviction for threatening in the second degree and breach of the peace in the second degree arose out of statements he made to an attorney that represented the Town of Waterford in a zoning dispute with Defendant. On appeal, Defendant argued that his statements were protected by the First Amendment to the Federal Constitution because they were not real or true threats. The Appellate Court affirmed. The Supreme Court reversed, holding that Defendant was entitled to a judgment of acquittal on both charges, as Defendant’s statements did not rise to the level of a true threat and were therefore entitled to the protection of the First Amendment despite their inflammatory nature. View "State v. Krijger" on Justia Law

After a jury trial, Petitioner was convicted of sexual assault in the first degree and risk of injury to a child. The Appellate Court affirmed the convictions on direct appeal. Petitioner later sought habeas relief, claiming that his appellate counsel provided ineffective assistance by failing to investigate Petitioner’s claims that he had a history of sexually transmitted diseases and to introduce evidence concerning whether the victim had contracted any such diseases. The habeas court rejected Petitioner’s claim. The Appellate Court affirmed. The Supreme Court affirmed, holding that Petitioner failed to demonstrate that he was prejudiced by any deficiency in counsel’s performance. View "Anderson v. Comm'r of Corr." on Justia Law

After a jury trial, Defendant was convicted of one count of murder and one count of felony murder. The Supreme Court affirmed, holding that the trial court (1) properly admitted evidence of uncharged sexual misconduct; (2) properly rejected Defendant’s claim under Brady v. Maryland that he was denied a fair trial because the state failed to disclose an alleged agreement or understanding with a key witness that she would be given a benefit if she testified for the state, as there was no agreement or understanding between the witness and the state prior to her testimony; and (3) properly permitted the prosecutor to exercise a peremptory challenge with respect to an African-American venireperson. View "State v. Smith" on Justia Law

Defendant was convicted after a jury trial of one count of felony murder. The Supreme Court affirmed, holding (1) the trial court’s decision to preclude the testimony of a key defense witness did not rise to the level of a constitutional violation, nor was it improper on purely evidentiary grounds; (2) Defendant’s claims of prosecutorial impropriety during cross-examination and closing argument were without merit; (3) Defendant’s argument that his conviction was fundamentally unfair because the State relied on a different theory in his case than in the case against an alleged coassailant was without merit; (4) the evidence was sufficient to support Defendant’s conviction for felony murder; and (5) the trial court did not err in denying Defendant’s motion to suppress oral and written statements to the police confessing his role in the murder. View "State v. Andrews" on Justia Law

After a jury trial, Defendant was convicted of operating a motor vehicle while under the influence of intoxicating liquor and operating a motor vehicle while having an elevated blood alcohol content. Defendant was also convicted of speeding. The Supreme Court affirmed the judgment of the trial court, holding (1) the trial court properly denied Defendant’s motion to suppress breath test reports, as the state experts who testified regarding certain breath tests fulfilled the requirements of Melendez-Diaz v. Massachusetts; and (2) the trial court properly denied Defendant’s motion to suppress the evidence resulting from his arrest, as the constable who made the arrest in the present case was a duly qualified special constable with the power to make the arrest. View "State v. Buckland" on Justia Law

Defendant was convicted on a conditional plea of nolo contendere of possession of narcotics with intent to sell. Defendant appealed the district court’s denial of his motion to suppress evidence that the police discovered after stopping Defendant incident to the detention of another individual, who was wanted for a violation of probation, while Defendant and the individual were walking together on a sidewalk. Defendant appealed, arguing that the officers had seized him in violation of Terry v. Ohio because they lacked a reasonable and articulable suspicion that Defendant had committed or was about to commit a crime. The Appellate Court affirmed the denial of Defendant’s motion to suppress, concluding that it is permissible for the police to briefly detain the companion of a suspect, incident to the lawful stop of the suspect, even though the police lack reasonable suspicion to believe the companion has engaged in or is engaging in criminal behavior. The Supreme Court affirmed, holding that the police were authorized to stop and briefly detain Defendant, as a reasonable safety measure, in connection with the lawful detention of the individual he was accompanying because the police reasonable believed that the other individual was armed and dangerous. View "State v. Kelly" on Justia Law

After a jury trial, Defendant was convicted of murder and sentenced to fifty years imprisonment. Defendant appealed, contending that he had been deprived of a fair trial because of improper statements made by the prosecutor during trial and in closing argument. The Appellate Court affirmed the judgment of conviction, concluding that only certain statements by the prosecutor were improper, and Defendant was not deprived of a fair trial as a result. Defendant and the State separately appealed. The Supreme Court affirmed, holding (1) the State’s appeal must be dismissed because the State was not aggrieved by the judgment of the Appellate Court; and (2) Defendant was not deprived of a fair trial. View "State v. Albino" on Justia Law

After a jury trial, Defendant was convicted of various criminal offenses in connection with the shooting of Johnnie Jones. On appeal, Defendant argued that the victim’s conduct in identifying Defendant as the perpetrator was unduly suggestive in violation of his due process rights. At issue before the Supreme Court was whether the due process clauses of the Connecticut constitution provide protection against allegedly unduly suggestive eyewitness identification procedures undertaken by a private actor, even in the absence of any improper state action. The Supreme Court affirmed the convictions, holding (1) any eyewitness identifications that are not tainted by any unduly suggestive state action do not implicate due process principles unless the identification was so unreliable that its admission deprived the defendant of his right to a fair trial; and (2) because Defendant’s claim in this case that the victim’s identification of him as the perpetrator should be suppressed on the ground that it was unduly suggestive did not implicate the state constitution, and because Defendant did not raise the claim at trial, it was not reviewable. View "State v. Johnson" on Justia Law