Justia Constitutional Law Opinion Summaries

After a jury trial, Defendant was convicted of sexual assault in the first degree and risk of injury to a child. The Supreme Court reversed the judgment of the trial court and remanded for a new trial, holding (1) the trial court abused its discretion by improperly precluding Defendant from introducing, on relevancy grounds, evidence of prior sexual conduct that was admissible under the rape shield statute, in violation of Defendant’s federal and state constitutional rights to confrontation; and (2) the trial court’s preclusion of the evidence was not harmless beyond a reasonable doubt. View "State v. Shaw" on Justia Law

After a jury trial, Defendant was convicted of several crimes. On appeal, Defendant argued that, during sentencing, the trial court deprived him of his due process rights by improperly considering that Defendant decided to proceed to trial rather than accept a plea bargain. The Appellate Court declined to review Defendant’s sentencing claim on the grounds that it was unpreserved and that Defendant had not properly made an “affirmative request” for review in his main brief under State v. Golding. The Supreme Court reversed in part, holding (1) the requirement that a defendant must “affirmatively request” Golding review in his main brief in order to receive appellate review of unpreserved constitutional claims is overruled, and therefore, the Appellate Court improperly declined to review Defendant’s constitutional claims on that ground; (2) Defendant failed to establish that the trial court penalized him for exercising his right to a jury trial; but (3) the use of the Court’s supervisory authority was warranted to prevent adverse effects on the public’s perception of the inherent fairness of the criminal justice system that may arise when a trial judge could appear to have considered a defendant’s decision to exercise his right to a trial during sentencing. Remanded for a new sentencing hearing. View "State v. Elson" on Justia Law

After a jury trial, Defendant was convicted of murder and other crimes. The Supreme Court (1) reversed the judgment of the trial court as to Defendant’s convictions for the crimes of kidnapping in the second degree and burglary in the first degree, holding that certain evidence relating to the potential impeachment of a key prosecution witness should have been admitted at trial, and that the failure to admit the evidence was not harmless beyond a reasonable doubt as to those counts; and (2) affirmed the trial court in all other respects, holding that the court did not err in its instructions to the jury and that the prosecutor did not engage in misconduct. View "State v. Baltas" on Justia Law

Plaintiff, who worked for Defendant as a plumber, brought this action seeking payment of overtime wages for, among other things, his daily commute between his home and the job sites. The trial court concluded that Defendant was not entitled to overtime compensation for his travel time between home and work because the Fair Labor Standards Act (FLSA) preempted the relevant Connecticut laws and regulations governing overtime and travel time. The Supreme Court affirmed, holding that because section 31-60-10 of the Regulations of Connecticut State Agencies, as applied to the facts of this case, confers lesser benefits on employees than those afforded under the FLSA, federal preemption applies, and therefore, Plaintiff was not entitled to compensation for his commuting time. View "Sarrazin v. Coastal, Inc." on Justia Law

Defendant pled nolo contendere to possession of narcotics with intent to sell to sell by a person who is not drug-dependent, possession of narcotics with intent to sell within 1500 feet of a school, and possession of a weapon in a motor vehicle. Defendant appealed, arguing that the trial court erred in denying his motion to suppress with respect to the narcotics and handgun found in a plastic bag inside the trunk of his vehicle. Specifically, Defendant argued that the search of bags inside the trunk of his vehicle could not be conducted within the automobile exception to the warrant requirement under the Connecticut constitution. The Supreme Court affirmed, holding that the state constitution does not prohibit the warrantless search of a closed container located in the trunk of a vehicle conducted during an otherwise constitutional warrantless search of a vehicle. View "State v. Williams" on Justia Law

Upon responding to a 911 call from a tenant of a rooming house reporting a disturbance involving a gun, police officers entered an unlocked attic space in the house and retrieved marijuana and a gun. After a jury trial, Defendant, who resided in a room on the third floor of the house, was convicted of attempt to commit criminal possession of a firearm, criminal possession of a pistol, and possession of marijuana with intent to distribute. Defendant appealed the denial of his motion to suppress the evidence seized by the police as products of an unlawful search, claiming he had a reasonable expectation of privacy in the attic. The appellate court affirmed, holding that, because of Defendant’s lack of control over the access of others to the attic, Defendant did not have an expectation of privacy in that space that society would recognize as reasonable. The Supreme Court affirmed, holding that appellate court properly resolved the issue by virtue of its well-reasoned decision. View "State v. Pierre" on Justia Law

Upon following up on complaints from Defendant’s neighbor relating to Defendant’s keeping of animals in his residence, a police officer concluded that a “welfare check” was necessary and made a warrantless entry into Defendant’s home. Defendant subsequently entered a plea of nolo contendere to two counts of cruelty to animals. Defendant appealed the trial court’s denial of his motion to suppress on the ground that the warrantless entry was justified under the emergency exception to the warrant requirement. The appellate court reversed, concluding that the evidence did not permit a finding that the police reasonably believed that a warrantless entry was necessary to help a person inside the dwelling who was in immediate need of assistance. The Supreme Court reversed, holding that the trial court properly concluded that, under the totality of the circumstances present in this case, a police officer reasonably would have believed that an emergency existed inside Defendant’s home. View "State v. DeMarco" on Justia Law

Walter Hopkins was severely injured as a result of the second of two vehicle collisions. Hopkins was the passenger in an Infiniti, which struck the side of a vehicle driven by Matthew Vincent, a volunteer firefighter. Vincent pursued the Infiniti at high speeds in his vehicle, at which time he relayed information via cell phone regarding the Infiniti and its location to Ellen Vece, a 911 dispatcher employed by the Town of Clinton. The Infiniti eventually crashed into a tree. Hopkins required permanent care as a result of his injuries. An action was filed on Hopkins' behalf against the Town, among others. The jury found in favor of the plaintiff, finding (1) the Town was liable under the identifiable person-imminent harm exception to governmental immunity; and (2) Vece’s failure to act was a proximate cause of Hopkins’ injuries. The Supreme Court reversed, holding that the identifiable person-imminent harm exception to the doctrine of governmental immunity did not apply in this case because the circumstances would not have made it apparent to Vece that her failure to instruct Vincent to stop following the Infiniti likely would have subjected Hopkins to imminent harm. View "Edgerton v. Town of Clinton" on Justia Law

After a jury trial, Defendant was found guilty of two drug-related offenses following a police investigation that culminated in the seizure of heroin from defendant’s home pursuant to a search warrant. Defendant appealed, arguing, among other things, that the trial court erred in denying her motion to suppress certain statements because the statements had been obtained when a police officer interrogated her during the execution of the search warrant without first advising her in accordance with Miranda v. Arizona. The appellate court affirmed the convictions, determining that, at the time of the police questioning, Defendant was not in custody for purposes of Miranda, and therefore, Miranda warnings were not required. The Supreme Court reversed, holding (1) Defendant was in custody when she was questioned by the police officer, and, as a result, the police were required to advise her of her rights under Miranda; and (2) the Miranda violation was not harmless beyond a reasonable doubt. View "State v. Mangual" on Justia Law

Fairchild Heights Residents Association, Inc. (Association), filed suit against Defendant, Fairchild Heights, Inc., for negligence and violations of the Connecticut Unfair Trade Practices Act (CUTPA). The trial court found in favor of Defendant on all counts. The Association appealed, arguing that the appellate court erred in concluding that it failed to exhaust its administrative remedies before requesting declaratory relief and that it did not have standing to bring an action under CUTPA. The Supreme Court reversed in part, holding that the Association had standing to assert a CUPTA claim, as (1) there was no administrative remedy the association could have exhausted to obtain the relief it sought before bringing its CUTPA claim; and (2) the Association did not require the participation of all its individual members to allege ascertainable loss for the purpose of obtaining injunctive and other equitable relief under CUTPA. Remanded for a new trial on Plaintiff’s CUTPA claim. View "Fairchild Heights Residents Ass'n, Inc. v. Fairchild Heights, Inc." on Justia Law