Justia Constitutional Law Opinion Summaries

Pursuant to a plea agreement, Petitioner pleaded guilty to manslaughter in the first degree with a firearm. The plea agreement stated that Petitioner would receive a total sentence of between twenty and twenty-five years’ imprisonment and that defense counsel had a right to argue for a sentence beneath the twenty-five year cap. At sentencing, defense counsel agreed with the prosecutor’s recommendation that the trial court should impose the maximum sentence under the agreement. The trial court sentenced Petitioner to twenty-five years imprisonment. Petitioner subsequently filed a petition for a writ of habeas corpus, claiming ineffective assistance of counsel. The habeas court denied relief, determining that Petitioner failed to prove ineffective assistance of counsel under Strickland v. Washington. The Appellate Court affirmed, concluding that the habeas court properly determined that Petitioner failed to prove actual prejudice under Strickland. The Supreme Court reversed in part, holding that the habeas court improperly applied Strickland to Petitioner’s ineffective assistance claim because a complete breakdown in the adversarial process occurred, and therefore, Petitioner’s claim was instead controlled by United States v. Cronic, under which prejudice should be presumed. View "Davis v. Comm’r of Corr." on Justia Law

When thirty-one-year-old Bill Smolinski disappeared, Defendants, Bill’s mother and sister, began to pressure Plaintiff, Bill’s former girlfriend, into cooperating with the investigation by saying disparaging things to Plaintiff’s acquaintances and posting missing person flyers depicting Bill along Plaintiff’s school bus route and near her home. Plaintiff brought this action claiming defamation and intentional infliction of emotional distress. The trial court entered judgment awarding Plaintiff compensatory and punitive damages on her claims. The Appellate Court affirmed. The Supreme Court reversed and remanded for a new trial, holding that the trial court’s findings on Plaintiff’s claims of defamation and intentional infliction of emotional distress did not consider - and were not consistent with - the First Amendment limitations placed on these torts. View "Gleason v. Smolinski" on Justia Law

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