Justia Constitutional Law Opinion Summaries

Articles Posted in Connecticut Supreme Court
by
The Supreme Court affirmed the judgment of the appellate court affirming the judgment of the trial court denying Defendant's motion to correct an illegal sentence, holding that the legislature may and has remedied the constitutional violation in this case with parole eligibility. Defendant, a juvenile offender, was convicted of murder and other offenses. Defendant was originally sentenced to imprisonment for the functional equivalent of his lifetime without the possibility of parole. Subsequently, decisions by the United States and Connecticut Supreme Courts and enactments by the legislature resulted in changes to the sentencing scheme for juvenile offenders. As a result, Defendant will be parole eligible when he is about fifty years old. Defendant filed a motion to correct an illegal sentence based on Miller v. Alabama, 467 U.S. 460 (2012). The trial court ultimately dismissed the motion, concluding that Defendant's claim was moot in light of the United States Supreme Court's holding that Miller applied retroactively. The Supreme Court affirmed, holding (1) parole eligibility afforded by No. 15-84 of the 2015 Public Acts (P.A. 15-84) is an adequate remedy for a Miller violation under the Connecticut constitution; and (2) P.A. 15-84, 1 does not violate the separation of powers doctrine or Defendant's right to equal protection under the federal constitution. View "State v. McCleese" on Justia Law

by
The Supreme Court affirmed the judgment of the appellate court upholding Defendant's convictions for several offenses stemming from the sexual assault of his minor daughter, holding that the evidence was sufficient to support Defendant's conviction for three counts of criminal violation of a restraining order and that the prosecutor did not commit misconduct. Specifically, the Court held (1) there was sufficient evidence from which the jury could conclude that Defendant had "knowledge of the terms of the order" because the court expressly instructed Defendant to limit contact with the children and Defendant heard Spanish language translations of the terms of the order; and (2) the prosecutor's comments and questions were not improper. View "State v. Elmer G." on Justia Law

by
In this medical negligence action, the Supreme Court affirmed the judgment of the trial court rendered in accordance with the court's granting of Defendants' motions to dismiss and for summary judgment, holding that the Court could not reach the merits of Plaintiff's claim that Conn. Gen. Stat. 52-190a is unconstitutional. Plaintiff brought this case against the State and numerous superior court judges, a psychiatrist and his employer, and business entities after his wife committed suicide. The trial court granted judgment for Defendants. On appeal, Plaintiff argued that section 52-190a, which requires a plaintiff to append a good faith certificate and supporting opinion letter to the complaint in cases of medical negligence, is unconstitutional. The Supreme Court affirmed, holding that because Plaintiff failed to challenge the trial court's threshold conclusions that his claims against Defendants were barred by, among other things, the doctrines of res judicata and collateral estoppel, this Court could not address the single substantive issue that Plaintiff raised and that the judgment of the trial court must be affirmed. View "Traylor v. State" on Justia Law

by
The Supreme Court reversed in part the judgment of the Appellate Court concluding that Defendant failed to establish that his Sixth Amendment right to confront witnesses against him was violated at trial, holding that, under the specific circumstances of this case, Defendant established a violation of his right to confrontation. Defendant was found guilty of felony murder, manslaughter in the first degree with a firearm, and other offenses. At trial, the State introduced evidence that Defendant's DNA profile, which had been generated from a post arrest buccal swab, matched the DNA found on evidence from the crime scene. The State, however, did not call as a witness the analyst who processed the buccal swab and generated the DNA profile used in the comparison. On appeal, the Appellate Court concluded that Defendant's Sixth Amendment claim failed because the admission of DNA evidence did not violate Defendant's constitutional right to confrontation. The Supreme Court reversed, holding that the generation of DNA's profile was testimonial and that Defendant's Sixth Amendment right to confront witnesses against him was violated. View "State v. Walker" on Justia Law

by
The Supreme Court affirmed the judgment of the Appellate Court dismissing Appellant's appeal from the judgment of the habeas court denying Appellant's amended petition for a writ of habeas corpus, holding that Appellant failed to meet his burden of showing that his criminal trial counsel rendered ineffective assistance by failing to present the testimony of a second alibi witness to support his defense. On appeal, Appellant claimed that the Appellate Court incorrectly concluded that the habeas court did not abuse its discretion in denying certification to appeal because he established that his counsel had performed deficiently. The Supreme Court disagreed, holding (1) it was not debatable among jurists of reason that Appellant rendered ineffective assistance; and (2) therefore, the Appellate Court correctly concluded that the habeas court did not abuse its discretion in denying Appellant's petition for certification to appeal. View "Meletrich v. Commissioner of Correction" on Justia Law

by
The Supreme Court affirmed the judgment of the trial court determining that Plaintiff's various statements and gestures regarding gun violence and mass shootings that led to his expulsion from the university were true threats that were not protected by the First Amendment to the United States Constitution, holding that Plaintiff's statements and gestures made on a public university campus were true threats. A university expelled Plaintiff from the university's campus after finding that Plaintiff's statements and actions with respect to gun violence had violated four provisions of the university's student code of conduct. Plaintiff brought this action alleging, among other things, that his expulsion violated his constitutional rights to due process and to freedom of speech. The trial court entered judgment in favor of Defendants. Plaintiff appealed, asserting that his statements and gestures were hyperbolic and humorous statements on a matter of public concern. The Supreme Court disagreed, holding that Plaintiff's statements and gestures were true threats that were not protected by the First Amendment. View "Haughwout v. Tordenti" on Justia Law

by
The Supreme Court affirmed Defendant's conviction of sexual assault in a cohabiting relationship, holding that alleged improper comments made by the prosecutor during closing argument and cross-examination did not warrant reversal of Defendant's conviction. On appeal, Defendant argued that the prosecutor made an impermissible "generic tailoring" argument by commenting in closing argument that the jury should discredit Defendant's trial testimony and that this comment violated his confrontation rights under the Connecticut Constitution. Defendant further argued that the prosecutor engaged in impermissible conduct in violation of his due process right to a fair trial pursuant to State v. Singh, 793 A.2d 226 (Conn. 2002). The Supreme Court affirmed, holding (1) the prosecutor's tailoring comment constituted a specific, rather than a generic, tailoring argument; and (2) assuming that Singh was violated, Defendant was not deprived of his due process right to a fair trial. View "State v. Weatherspoon" on Justia Law

by
The Supreme dismissed the writ of error filed by Appellant, who was suspended from the practice of law before the appellate court for a six-month period, holding that an additional order issued by the appellate court in 2018 clarifying the previous order did not violate the ex post facto clause in violation of the United States Constitution. In 2014, the appellate court issued its order suspending Appellant from practice and barring her from representing any client before the appellate court until she filed a motion for reinstatement and that motion had been granted. In 2018, the appellate issued issued an additional order clarifying that the 2014 order precluded Appellant from providing "legal services of any kind in connection with any" appellate court matter until she filed a motion for reinstatement and that motion had been granted. Appellant filed a writ of error, arguing, among other things, that the 2018 order was an unconstitutional ex post facto law because it retroactively prohibited her from engaging in certain conduct. The Supreme Court dismissed the writ of error, holding that the 2018 did not violate the ex post facto clause or Appellant's due process rights and that Appellant's claims of selective enforcement and discriminatory and retaliatory treatment were not reviewable by the Court. View "Cimmino v. Marcoccia" on Justia Law

by
The Supreme Court reversed Defendant's murder conviction and remanded the case for a new trial, holding that the trial court erred in denying Defendant's motion to suppress. Defendant was arrested for drug offenses and the murder of the victim. Five days after Defendant's rent was due for a second month the police searched his apartment without a warrant. The police discovered the victim's cell phone hidden in a bathroom wall. Defendant moved to suppress the evidence. The trial court denied the motion, concluding that Defendant did not have a subjective expectation of privacy in the apartment at the time of the search because the lease had expired and Defendant had failed to make rent payments and to secure his belongings in the apartment. The Supreme Court reversed, holding (1) under the facts of this case, Defendant established that the apartment was his home and neither his incarceration or his failure to pay rent five days after it was due divested him of his subjective expectation of privacy in his apartment; and (2) because the State did not argue that any error was harmless, the case is remanded for a new trial. View "State v. Jacques" 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 possession of narcotics with intent to sell by a person who is not drug-dependent, holding that the admission of certain hearsay evidence was erroneous, but the error was not of constitutional dimension and was not harmful. The hearsay statements at issue were used to establish that Defendant was the de facto owner of a vehicle registered to a third party. Defendant was a passenger in the vehicle when police officers discovered bricks of heroin and a large sum of cash. On appeal, Defendant argued that the admission of the hearsay statements, which were based on vehicle inspection records, violated his constitutional right to confront a witness against him. The Appellate Court affirmed the judgment of conviction. The Supreme Court affirmed, holding that the statements regarding the inspection were testimonial but that improper admission of the hearsay evidence was not harmful. View "State v. Sinclair" on Justia Law