Justia Constitutional Law Opinion Summaries

After a jury trial, Defendant was convicted of several crimes and sentenced to a term of imprisonment of fifty-five years for felony murder, twenty years for first degree robbery, and five years for carrying a pistol without a permit, each to run concurrently. Defendant subsequently filed a motion to correct an illegal sentence, claiming that felony murder was an unclassified felony subject to a maximum term of imprisonment of twenty-five years. The trial court denied the motion. The Supreme Court affirmed, holding that the trial court's sentence was proper because felony murder is not an unclassified felony but, rather, a felony classified as murder and, as such, is punishable by a term of imprisonment of twenty-five years to life. View "State v. Adams" on Justia Law

Claimant brought a claim before the Claims Commissioner seeking damages from the State as the coadministrator of the estate of her deceased daughter, who had died while confined in a correctional institution. In the course of Claimant's case, the Commissioner issued subpoenas to the Charlotte Hungerford Hospital requesting information about the decedent's treatment there. The Hospital refused to comply with the subpoena, arguing that the Commissioner had no authority to issue subpoenas to nonparties. The trial court enforced the Commissioner's subpoena, and the appellate court affirmed. Subsequently to the Supreme Court's certification of the Hospital's appeal, Claimant settled underlying case, and consequently, the State no longer sought to enforce the subpoenas. The Supreme Court dismissed the Hospital's appeal as moot and vacated the judgments of the lower courts, as the Court could no longer grant relief. View "State v. Charlotte Hungerford Hosp." on Justia Law

After a jury trial, Defendant was convicted of kidnapping in the first degree, attempt to commit robbery in the first degree, and assault in the first degree. The appellate court affirmed the judgment of conviction. Defendant appealed, contending that the appellate court erred in concluding that the trial court's failure to give a Ledbetter instruction, sua sponte, did not present the type of extraordinary circumstance that warranted reversal under the plain error doctrine. Under State v. Ledbetter, trial courts are required to provide a jury instruction regarding the increased risk of misidentification when an eyewitness is not advised that the perpetrator of a crime may or may not be present in the identification procedure in cases in which the identification procedure administrator had failed to provide such a warning. The Supreme Court affirmed, holding that the appellate court properly concluded the failure to give a Ledbetter instruction in this case was not plain error. View "State v. Sanchez" on Justia Law

After a jury trial, Defendant was convicted of the sale of narcotics within 1500 feet of a school in violation of Conn. Gen. Stat. 21a-278a(b). Defendant appealed, arguing that criminal liability under section 21a-278a(b) did not attach in his case because the drug transaction began within 1500 feet of a school but culminated elsewhere. The appellate court reversed, concluding that the evidence was insufficient to support Defendant's conviction because section 21a-278a(b) required the state to prove that Defendant had effected a delivery of drugs within 1500 of the school, and the state had failed to prove that the physical transfer occurred within that 1500 foot zone. The Supreme Court reversed, holding (1) the appellate court construed the statutory definition of sale of a controlled substance under Conn. Gen. Stat. 21a-240(50) too narrowly, and therefore, there was sufficient evidence to support Defendant's conviction in this case; and (2) Defendant waived his claim that the trial court improperly instructed the jury regarding the intent element of the offense. View "State v. Webster" on Justia Law

After a jury trial, Defendant was convicted of criminally possessing a firearm and several drug-related crimes. The appellate court affirmed Defendant's convictions. Defendant appealed. After noting that the appellate court properly resolved the issues Defendant brought up on appeal with a concise and well reasoned opinion, the Supreme Court affirmed, holding that the appellate court (1) properly concluded that Defendant's right to due process under the Connecticut constitution was not violated by the state's inability to produce audio recordings of certain drug transactions; and (2) properly concluded that the trial court did not abuse its discretion in denying Defendant's motion to dismiss. View "State v. Barnes" on Justia Law

After a jury trial, Defendant was convicted of assault in the first degree and attempt to commit assault in the first degree. Defendant appealed, arguing that the trial court erred by denying Defendant's request that the jury be instructed on the theory that Defendant was acting in defense of another. The appellate court reversed and remanded for a new trial, concluding that the trial court's refusal to charge the jury on the defense of others was improper. The Supreme Court reversed, holding that the evidence in the record was insufficient to support Defendant's request to have the jury instructed on the defense of others, and therefore, the trial court properly refused to instruct the jury as requested. Remanded with direction to affirm the judgment of the trial court. View "State v. Bryan" on Justia Law

This litigation was the latest chapter in the efforts of Plaintiffs, including the commissioner of environmental protection, to close and remediate an area known as the "tire pond," a solid waste disposal area on land owned by Defendants, an individual and various corporate entities he owned or controlled. The nonparty plaintiff in error, Corporation, which conducted its business on land leased from an industrial park that contained a portion of the tire pond, brought this writ of error from the judgment of the trial court ordering it to vacate that land in order to effectuate the environmental remediation that the trial court had ordered in the action underlying this writ of error. The Supreme Court dismissed the writ of error, holding that the trial court properly ordered Corporation to vacate where (1) the trial court had the authority to enforce the injunctions ordered in the underlying action against Corporation; (2) such an order was necessary to effectuate the remediation; and (3) the trial court's enforcement of the injunctive orders rendered in the underlying action against Corporation did not violate Corporation's due process rights. View "Comm'r of Envtl. Prot. v. Farricielli" on Justia Law

Defendant was charged with aiding and abetting murder, felony murder, home invasion, and burglary in the first degree. Defendant elected a trial to a three judge court. The panel found Defendant guilty on all of the charges. Defendant appealed, contending that there was insufficient evidence to convict him of aiding and abetting murder and that he did not knowingly waive his right to a jury trial. The Supreme Court (1) reversed in part with respect to Defendant's conviction of aiding and abetting murder, as the evidence was insufficient to convict Defendant on that count; and (2) concluded that Defendant's waiver of his right to a jury trial was valid. Remanded. View "State v. Bennett" on Justia Law

After a jury trial, Defendant was convicted of murder, capital felony, carrying a pistol without a permit, and criminal possession of a firearm. Defendant appealed, raising three claims relating to testimony and demonstrative evidence of his flight from police after the commission of the crimes, which were admitted as evidence of his consciousness of guilt. The Supreme Court affirmed, holding (1) the trial court did not abuse its discretion in finding that the prejudicial impact of the admission of the evidence of flight did not outweigh its probative value; and (2) Defendant failed to preserve his claim that the trial court improperly failed to give the jury a limiting instruction on uncharged misconduct evidence, and Defendant was not entitled to relief on this claim under the plain error doctrine or under the Court's supervisory authority. View "State v. Hill" on Justia Law

Pictometry International Corporation was engaged in the business in selling specialized aerial photographic services. Pictometry contracted with the department of information technology to license the department of environmental protection (DEP) to use certain aerial photographic images and associated data that were owned and copyrighted by Pictometry. Stephen Whitaker requested that the DEP provide him with the images and data. The DEP indicated that it would provide copies of the images for a fee provided for in the licensing agreement. Whitaker filed a complaint against the DEP with the freedom of information commission (commission). The commission determined that, pursuant to the Freedom of Information Act (act), the DEP was required to provide Whitaker with the images at minimum cost but was not required to provide the associated data. The trial court affirmed. The Supreme Court reversed and remanded, holding (1) the commission improperly ordered the DEP to provide copies of the images without first determining whether it was feasible for the DEP to provide such copies and whether doing so would pose a public safety risk; and (2) if the commission determined on remand that Whitaker is entitled to copies of the images, Whitaker was required to pay a $25 per image fee. View "Pictometry Int'l Corp. v. Freedom of Info. Comm'n" on Justia Law