Justia Constitutional Law Opinion Summaries

Defendant was arrested without a warrant and charged with several crimes. Defendant filed a motion to be released without bond because a probable cause finding had not been made within forty-eight hours of his arrest. The trial court denied Defendant's motion. The appellate court upheld the trial court's decision. The Supreme Court affirmed, holding that, under the specific facts of this case, any violation of Defendant's Fourth Amendment rights was de minimis where (1) Defendant was present in the courthouse awaiting arraignment, at which point probable cause findings are typically made, prior to the expiration of the forty-eight hour period; and (2) the trial court found probable case for Defendant's arrest less than two hours after expiration of the forty-eight hour time period. View "State v. Heredia" on Justia Law

Petitioner was charged with various criminal offenses in two informations. After a jury trial, Petitioner was convicted of sexual assault in the second degree, assault in the second and third degrees, and risk of injury to a child. After the convictions were affirmed on appeal, Petitioner filed a petition for a writ of habeas corpus, alleging ineffective assistance of counsel. The habeas court found Petitioner's pretrial counsel had rendered ineffective assistance by failing to provide Petitioner with adequate advice regarding a pretrial plea offer and ordered the trial court to resentence Petitioner in accordance with the sentence proposed in the plea offer. The appellate court affirmed. The Supreme Court reversed, holding that the habeas court improperly circumvented the trial court's discretion to impose an appropriate sentence. Remanded. View "H.P.T. v. Comm'r of Corr." on Justia Law

After a jury trial, Defendant was convicted of risk of injury to a child and sexual assault in the fourth degree. The Supreme Court reversed the trial court's judgment, holding (1) the prosecutor made improper statements during closing arguments and in connection with defense counsel's cross-examination of key state's witnesses, and the prosecutorial impropriety deprived Defendant of his due process right to a fair trial; and (2) the trial court improperly admitted into evidence a video recording and transcript of a forensic interview of the victim under the tender years exception to the hearsay rule without first conducting a hearing. Remanded for a new trial. View "State v. Maguire" on Justia Law

After a jury trial, Defendant was found guilty of breach of the peace in the second degree and harassment in the second degree for allegedly threatening a coworker during a telephone call. The appellate court reversed, concluding (1) the trial court improperly failed to instruct the jury that it could find Defendant guilty of the breach of the peace charge only if it found Defendant's offending speech was a real or true threat not entitled to protection under the First Amendment; and (2) where the telephone harassment statute bars conduct only, the evidence was insufficient to convict Defendant of the harassment charge because the the case was predicated entirely on Defendant's speech. The Supreme Court affirmed, holding (1) the jury instructions on the breach of the peace charge were inadequate to ensure Defendant was not convicted on the basis of constitutionally protected speech; and (2) the telephone harassment statute applied to speech as well as conduct, but because Defendant did not have fair notice that she could be subjected to punishment for the verbal content of the telephone call, the harassment charge must be dismissed. View "State v. Moulton" on Justia Law

Complainants, an attorney and the Office of the Chief Public Defender, submitted a request for a declaratory ruling to the Connecticut Medical Examining Board asking whether physician participation in the execution of condemned inmates using lethal injection was permitted. Complainants then sent a letter regarding their request for a declaratory ruling. The Board convened an executive session to obtain legal advice about issues raised in the letter. Complainants then filed a complaint with the Commission, alleging that Plaintiffs, the Board and its chairperson, violated the Freedom of Information Act by convening in executive session during the meeting for "purposes not permitted" under the Act. The Commission determined the executive session was impermissible under the Act. The trial court upheld the Commission's decision. The Supreme Court affirmed, holding that the letter did not constitute notice of a pending claim as defined by Conn. Gen. Stat. 1-200, and therefore, the Board was not permitted to convene in executive session under the Act. View "Chairperson, Conn. Med. Examining Bd. v. Freedom of Info. Comm'n" on Justia Law

After a jury trial, Defendant was convicted of murder. Defendant appealed, contending, among other things, that statements he made to the court during a pretrial hearing and at sentencing indicating dissatisfaction with the performance of his appointed counsel resulted in a clear and unequivocal request invoking the right to self-representation under the Sixth Amendment. The appellate court affirmed Defendant's conviction, concluding that Defendant's statements to the court did not develop into a clear and unequivocal request for self-representation. The Supreme Court affirmed, holding that the trial court did not violate Defendant's right to self-representation during the criminal proceedings. View "State v. Pires" on Justia Law

Petitioner entered conditional pleas of nolo contendere to several felony offenses. The appellate court affirmed. Petitioner filed an amended petition for a writ of habeas corpus, alleging that his counsel rendered ineffective assistance. Petitioner's appellate counsel, who also served as his trial counsel, failed to file a petition for certification with the Supreme Court challenging the propriety of the appellate court's judgment. The habeas court granted the petition in part and ordered that Petitioner's right to file a petition for certification to appeal to the Supreme Court be restored. The appellate court reversed, concluding that Petitioner failed to introduce evidence that he was prejudiced by counsel's deficiency. The Supreme Court reversed, holding that Petitioner's habeas action was not justiciable because it was not ripe for adjudication. Remanded with direction to dismiss the habeas petition. View "Janulawicz v. Comm'r of Corr." on Justia Law

This case arose when plaintiff initiated a foreclosure action against defendant. At issue on appeal was whether the trial court had authority to open a judgment of foreclosure by sale and related supplemental judgments after title had passed to the purchaser when a series of errors by the court and the parties caused the purchaser to buy a property that, unbeknownst to him but actually known by the second mortgagee, was in fact subject to a first mortgage that was to be foreclosed shortly thereafter. The court concluded that the appellate court incorrectly determined that the purchaser lacked standing under the circumstances of the present case; defendants inadequately briefed the issue of 17 Ridge Road, LLC's standing to intervene as a defendant and, therefore, the issue was deemed abandoned; and the appellate court correctly determined that the passing of title divested the trial court of jurisdiction to open the judgment of foreclosure by sale. Accordingly, the court reversed the judgment of the appellate court insofar as that court concluded that the trial court lacked authority to open the supplemental judgments. View "Citibank, N.A. v. Lindland" on Justia Law

This case arose from disputes between the Department of Information Technology and Defendant, a computer equipment supplier, over two contracts between the parties. The Department filed this action against Defendant, alleging breach of contract and fraud claims. Defendant filed an amended counterclaim, alleging takings and due process violations. The Department moved to dismiss the takings and due process claims based on the State's sovereign immunity. The trial court determined that the Department had waived the State's sovereign immunity regarding Defendant's counterclaims by bringing this cause of action against Defendant. After a jury trial, the trial court awarded Defendant damages on its procedural due process counterclaim. The Supreme Court (1) reversed the judgment of the trial court in favor of Defendant on the procedural due process counterclaim, holding that the Department did not waive the state's sovereign immunity by initiating the present litigation, and therefore, the trial court lacked subject matter jurisdiction over Defendant's counterclaims; and (2) affirmed in all other respects. View "Chief Info. Officer v. Computers Plus Ctr., Inc." on Justia Law

After a jury trial, Defendant was convicted of burglary in the first degree. After Defendant was released from prison he was found to have violated the terms and conditions of his probation by engaging in criminal conduct. Accordingly, the trial court revoked Defendant's probation. Defendant appealed, claiming there was insufficient evidence to support the finding he had violated his probation. Before oral argument, however, Defendant pleaded guilty to the criminal charges upon which the finding rested. The appellate court subsequently dismissed as moot Defendant's appeal. Defendant appealed, arguing that his habeas corpus action collaterally attacking his criminal conviction revived the controversy such that mootness was averted. During the pendency of Defendant's appeal, the habeas court dismissed Defendant's habeas corpus action. The Supreme Court dismissed as moot Defendant's appeal, holding that dismissal of the habeas corpus action extinguished any claim to a live controversy in this appeal. View "State v. Milner" on Justia Law