Justia Constitutional Law Opinion Summaries

After a jury trial Defendant was convicted of felony murder, conspiracy to commit robbery in the third degree, and robbery in the first degree. The appellate court affirmed. At issue in this certified appeal was whether the trial court properly instructed the jury on the statutory exception to the duress defense set forth in Conn. Gen. Stat. 53a-14, when the State claimed that Defendant had intentionally or recklessly placed herself in a situation in which it was probable that she would be subjected to duress by voluntarily resuming her relationship with an abusive boyfriend. The Supreme Court affirmed the judgment of the appellate court on the ground that, even if the trial court's instruction on the statutory exception to the duress defense was improper, any impropriety was harmless.

Defendant Gary Weddle and the intervening Defendant, the conservation commission of the town of Fairfield, appealed from the trial court's decision granting the writ of quo warranto filed by Plaintiffs, certain concerned taxpayers of the town of Fairfield, and ordering Weddle's removal from the office of wetlands compliance officer. On appeal, the Supreme Court reviewed the procedural and substantive requirements for maintaining a quo warranto action. The Court affirmed the decision of the trial court, holding (1) plaintiffs demonstrated sufficient interest to establish standing to pursue the quo warranto action; and (2) the trial court properly granted Plaintiffs' writ of quo warranto on the basis that Weddle's appointment to the wetland compliance officer position violated the town charter by usurping the office of the conservation director.

Defendant was convicted of two counts of larceny in the first degree by false pretenses. The parties agreed that the appellate court properly concluded that the trial court improperly failed to instruct the jury that it could aggregate the value of the property stolen in individual thefts only if it first concluded that the thefts were part of one scheme or course of conduct. Defendant, however, argued that the appellate court improperly concluded that the improper instruction was harmless beyond a reasonable doubt. The Supreme Court affirmed the judgment of the appellate court, holding that the error was harmless because Defendant did not contest the issue and the evidence so overwhelmingly supported the determination that the multiple thefts were part of a single scheme that no reasonable jury could have concluded otherwise.

Plaintiff was summarily convicted of criminal contempt of court and sentenced to 120 days incarceration. Plaintiff petitioned for a writ of error, claiming that, because the trial court did not inform him of the charge against him or afford him an opportunity to present exculpatory or mitigating evidence, his conviction and sentence violated his due process rights. The Supreme Court dismissed the writ of error, holding (1) Plaintiff's claim was subject to the Court's review; (2) Plaintiff's conviction was proper, as the trial court substantially complied with Practice Book 1-16; and (3) to the extent that the state and federal constitutions embrace a requirement that a defendant in a summary contempt proceeding be afforded notice and an opportunity to allocute, the trial court substantially complied with that requirement.

Defendant was convicted following a jury trial of one count of risk of injury to a child and two counts of sexual assault in the first degree. Defendant appealed, claiming that the trial court denied his constitutional rights to present a defense and to due process by improperly precluding him from eliciting testimony from a pediatrician who had examined the victim regarding a statement that the victim had made to her. The Supreme Court affirmed, holding that Defendant abandoned his claim, as (1) the record was unclear weather the court in fact precluded Defendant from eliciting testimony regarding this statement, and (2) Defendant neither sought a clarification of the court's ruling nor sought to elicit testimony from the pediatrician regarding the statement.

Defendant Miguel C. was convicted, after a jury trial, of three counts of sexual assault in the first degree and three counts of risk of injury to a child. Defendant appealed, claiming that he was entitled to a new trial because the complainant improperly testified about an alleged confession by Defendant to his wife. The Supreme Court reversed the judgment of conviction and ordered a new trial, holding (1) the contested portion of the complainant's testimony was improperly admitted, as its probative value was outweighed by the prejudicial effect; and (2) the verdict was substantially affected by that testimony, and therefore, the error was harmful.

Defendant was convicted of assault of public safety personnel. The appellate court reversed the conviction on the ground that the trial court had compelled Defendant to wear identifiable prison clothing at his jury trial in contravention of his constitutional right to a fair trial. The Supreme Court affirmed the judgment of the appellate court on the alternative ground that reversing Defendant's conviction was warranted in the exercise of the Court's inherent supervisory authority over the administration of justice, holding (1) in the absence of a defendant's voluntary decision to stand trial before a jury in prison clothing, a court must ensure that the defendant has civilian clothing to wear at trial, and its failure to comply with this requirement will result in reversal of the defendant's conviction; and (2) the trial court in this case erred in compelling Defendant to stand trial in identifiable prison clothing.

Defendant Anthony Thompson was convicted of one count of murder and two counts of assault in the first degree. The Supreme Court affirmed, holding (1) the trial court applied the proper standard in admitting into evidence a statement to the police and a signed photographic array by a deceased eyewitness identifying Defendant as the shooter; (2) there was sufficient evidence to support the trial court's finding that Defendant had caused the death of the witness; and (3) even if the trial court improperly admitted evidence relating to the circumstances surrounding the death of the witness to show consciousness of guilt, the impropriety was harmless.

In this case a jury found that Marc Pascual hired Defendant Eduardo Santiago to murder the victim and that Defendant acted in concert with Matthew Tyrell to break into the victim's home and fatally shoot him. The jury then returned a verdict finding Defendant guilty of all the charged offenses in the ten count information, including capital felony. The trial court sentenced Defendant to death by lethal injection. The Supreme Court (1) affirmed the underlying judgment of conviction; but (2) reversed the judgment insofar as it imposed a sentence of death, holding that the trial court did not err when it reviewed the department of children and families' file in camera, but the scope of its review failed to disclose significant and relevant mitigating evidence, requiring that Defendant receive a new penalty phase hearing. Remanded to the trial court for a new penalty phase hearing, following a new in camera review of the department's files and disclosure of evidence material to Defendant's case in mitigation.

Following a jury trial, Defendant Daniel Golodner was convicted of two counts of interfering with an officer and two counts of reckless endangerment in the second degree in connection with a dispute over a neighbor's attempt to have their common property boundary surveyed. The Supreme Court affirmed the judgment in part and reversed the judgment in part with respect to the conviction on the second charge of reckless endangerment, holding that the trial court improperly denied Defendant's motion to dismiss the second charge of reckless endangerment for violation of the statute of limitations. Remanded with direction to render judgment of acquittal on that charge and for resentencing.