Justia Constitutional Law Opinion Summaries

Following a jury trial, Defendant Willie Coleman was convicted of murder in connection with the fatal stabbing of his girlfriend. Defendant appealed, contending that the state offered insufficient evidence to prove beyond a reasonable doubt his intent to kill the victim, that the trial court improperly instructed the jury that it could infer such intent from the number of wounds he had inflicted on her, and that an improper statement by the prosecutor in closing argument deprived him of a fair trial. The Supreme Court affirmed, holding (1) the evidence was sufficient in this case to demonstrate intent; (2) Defendant failed to preserve his claim challenging the jury instructions, and Defendant could not prevail under State v. Golding or the plain error doctrine; and (3) under the circumstances of this case, the prosecutor's remark in closing argument did not deprive Defendant of a fair trial.

Defendant William Coleman was serving a fifteen-year sentence following his convictions on charges pertaining to his relationship with his ex-wife when he went on a hunger strike. Following a trial, the trial court granted the former commissioner of correction's application for a permanent injunction authorizing the department of correction to restrain and force-feed Defendant to prevent life-threatening dehydration and malnutrition. Defendant was subsequently force-fed. The Supreme Court affirmed, holding that the trial court properly determined (1) the state's interests outweighed Defendant's common-law right to bodily integrity; (2) the forcible administration of artificial nutrition and hydration to Defendant did not violate his constitutional right to free speech and privacy; and (3) international law did not prohibit medically necessary force-feeding under such circumstances.

The local board of education of the City of Bridgeport passed a resolution requesting the state board of education to authorize the commissioner of education to reconstitute the local board. The state board voted to authorize the commissioner to reconstitute the local board. In three separate actions, former local board members and residents and electors of the City filed actions against the state board, local board, and others, alleging state statutory and constitutional violations. The trial court reserved the action for the advice of the Supreme Court. At issue was (1) whether the failure of the state board to require the local board to undergo and complete training, as mandated by Conn. Gen. Stat. 10-223e(h), rendered void the state board's authorization; and (2) whether the local board's resolution requesting that the state board authorize reconstitution resulted in a waiver of the state board's obligation to require training. The Supreme Court concluded (1) the state board's failure to require training rendered void its authorization of reconstitution under section 10-223e(h); and (2) the local board's resolution had no effect on the operation of the statute.

A jury found Defendant guilty of four drug-related crimes. The appellate court concluded that there was insufficient evidence to support Defendant's conviction of possession of narcotics with intent to sell within 1500 feet of a school in violation of Conn. Gen. Stat. 21a-278a(b) and possession of drug paraphernalia with intent to use within 1500 feet of a school in violation of Conn. Gen. Stat. 21a-267(c) and remanded the case, directing the trial court to render judgment of not guilty on these charges. The Supreme Court affirmed in part and reversed in part, holding that the appellate court (1) properly held that there was insufficient evidence to support Defendant's conviction under section 21a-278a(b), but (2) improperly held that there was insufficient evidence to support Defendant's conviction under section 21a-267(c). Remanded for a new trial on the charge of possession of drug paraphernalia with the intent to use within 1500 feet of a school.

Plaintiff, the former town clerk of the town of Watertown, was removed from her position after she failed to report for work. Plaintiff subsequently filed a complaint against the town and certain of its officials (1) seeking a writ of mandamus ordering Defendants to restore her salary and benefits from the time they were discontinued and to continue such payments for the duration of her term, (2) claiming Defendants had violated her constitutional rights pursuant to 42 U.S.C. 1983, and (3) seeking recovery of her lost salary. The trial court granted Plaintiff's motion for partial summary judgment on counts one and three. The court, however, rendered judgment in favor of defendants on count two of the complaint based upon the jury's finding that there had not been a constitutional violation of due process. The Supreme Court reversed the judgment in part and remanded the case for further proceedings on counts one and three, holding that the trial court improperly concluded that Plaintiff had a clear legal right to be paid for the balance of her elected term unless or until she was removed from office.

Plaintiffs, the town of Bozrah and the town's zoning enforcement officer, brought an action seeking a temporary and permanent injunction to enjoin Defendants, owners and residents of certain property, from refusing to consent to an inspection of their property for zoning violations. The trial court granted a temporary injunction preventing Defendants from refusing to allow the inspection, concluding that pursuant to Camara v. Municipal Court, the reasonable governmental interest in stabilizing property values and promoting the general welfare justified an inspection in the present action. Defendants appealed, claiming that the trial court's order violated their right to be free from unreasonable searches and seizures. The Supreme Court reversed, holding (1) a zoning official may inspect a single property pursuant to Conn. Gen. Stat. 8-12 if the official first obtains an injunction issued upon probable cause by a judicial officer; and (2) because the trial court failed to make a preliminary determination of probable cause to believe that a zoning violation existed on the property, its order permitting a search of Defendants' property violated the Fourth Amendment. Remanded.

Defendant Rafael Crespo was convicted of one count of assault in the third degree and two counts of sexual assault in the first degree. Defendant's conviction stemmed from allegations that he had forcibly engaged in sexual intercourse with the victim and physically assaulted her on several occasions during their relationship. The appellate court affirmed. After analyzing the case under State v. Golding the Supreme Court affirmed, holding that the trial court properly excluded impeachment evidence regarding the victim's prior sexual conduct and that the exclusion of this evidence did not clearly violate Defendant's constitutional rights to confrontation and to present a defense.

After a jury trial, Defendant Leotis Payne was convicted of, inter alia, felony murder, robbery in the first degree, and attempt to tamper with a juror. The Supreme Court affirmed, holding (1) the trial court improperly joined for trial the felony murder and jury tampering cases against the Defendant for trial, but the error was harmless; (2) the trial court improperly admitted the testimony of one of the state's witnesses regarding an alleged threat made by Defendant, but the error was harmless; and (3) three statements by the prosecutor during closing and rebuttal arguments were improper, but those improprieties did not deprive Defendant of a fair trial, and therefore, Defendant was not entitled to a new trial due to the prosecutorial improprieties. In affirming the judgments of the trial court, the Court also overruled State v. King and its progeny, which recognized a presumption in favor of joinder in criminal cases.

Defendant Osibisa Hall pleaded guilty to one count of possession of marijuana with intent to sell and two counts of violation of a protective order. Defendant subsequently filed a motion to withdraw his guilty pleas and vacate the judgments of conviction, claiming that the trial court did not fulfill its obligation to address him personally and determine that he understood the immigration consequences of his pleas. The court denied the motion. The appellate court reversed, finding that the trial court failed to comply substantially with Conn. Gen. Stat. 54-1j when it neglected to personally address Defendant regarding the potential immigration consequences of his pleas. The Supreme Court reversed the appellate court, holding (1) substantial compliance with section 54-1j can be established even if the court does not address the defendant personally; and (2) the trial court substantially complied with section 54-1j in the present case.

In an underlying employment dispute, Employee sued Employer for discrimination. After the jury issued a verdict in favor of Defendant, Plaintiff moved for a new trial, alleging that Defendant had engaged in discovery misconduct. The trial court denied Plaintiff's motion. The appellate court affirmed. At issue before the Supreme Court was whether a party seeking a new trial on the basis of alleged knowing and deliberate discovery misconduct must show that the result at a new trial would likely be different. The Supreme Court affirmed, holding that the rule set forth in Varley v. Varley to determine whether a new trial should be granted on the basis of allegations that the judgment was obtained through fraud, as reframed in this decision, applies to motions for a new trial based on the discovery misconduct of the nonmoving party.