State of Connecticut v. Russell Peeler

Summary

The Supreme Court of Connecticut affirmed Russell Peeler's convictions for murder, two capital felonies, and conspiracy to commit murder, holding that the jury was properly instructed that it could convict on a capital felony under a Pinkerton conspiratorial-liability theory and that the errors in withholding the state's key witness's mental health records and in conducting ex parte hearings with her attorney were harmless beyond a reasonable doubt. On the state's cross-appeal, the court held the trial court abused its discretion both in denying the state permission to appeal and in denying its motion for a mistrial, because the court told the deadlocked penalty jury that failure to agree would compel a life sentence 'without the benefit of release,' an unsound legal premise that risked relieving the jury of sole responsibility for the life-or-death decision; it also rejected the defendant's alternate grounds, confirming that a new penalty jury may be impaneled and that Pinkerton/vicarious liability may prove aggravating factors. The court accordingly reversed the life sentence and remanded for a new penalty hearing on both capital felony counts. Chief Justice Sullivan concurred in the defendant's appeal but dissented from the state's appeal, viewing Caldwell as inapposite and the mistrial denial within the trial court's discretion; Justice Katz, joined by Justice Norcott, dissented on the categorical ground that the death penalty is cruel and unusual punishment.