constitutional due process claim in Connecticut

2017Co. , supra, 282 Conn. at 523, 923 A.2d 638 ("[a]s articulated in the seminal case of International Shoe Co. v. Washington , 326 U.S. 310 , 316, 66 S.Ct. 154 , 90 L.Ed. 95 (1945), the constitutional due process standard requires that, in order to subject a defendant to a judgment in personam, if he be not present within the territory of the forum, he have certain minimum contacts with it such that the maintenance of the suit does not offend traditional notions of fair play and substantial justice" [internal quotation marks omitted] ).

2017Co. , supra, 282 Conn. at 523, 923 A.2d 638 ("[a]s articulated in the seminal case of International Shoe Co. v. Washington , 326 U.S. 310 , 316, 66 S.Ct. 154 , 90 L.Ed. 95 (1945), the constitutional due process standard requires that, in order to subject a defendant to a judgment in personam, if he be not present within the territory of the forum, he have certain minimum contacts with it such that the maintenance of the suit does not offend traditional notions of fair play and substantial justice" [internal quotation marks omitted] ).

2018See, e.g., Chief Disciplinary Counsel v. Rozbicki , 326 Conn. 686 , 695, 167 A.3d 351 (2017) ("to permit a party to raise a claim on appeal that has not been raised at trial-after it is too late for the trial court or the opposing party to address the claim-would encourage trial by ambuscade, which is unfair to both the trial court and the opposing party" [internal quotation marks omitted] ); State v. Hilton , 45 Conn. App. 207 , 222, 694 A.2d 830 ("[w]e are not bound to consider claims of law not properly raised at trial"), cert. denied, 243 Conn. 925 , 701 A.2d 659 (1997), cert. denied, 522

2018See, e.g., Chief Disciplinary Counsel v. Rozbicki , 326 Conn. 686 , 695, 167 A.3d 351 (2017) ("to permit a party to raise a claim on appeal that has not been raised at trial-after it is too late for the trial court or the opposing party to address the claim-would encourage trial by ambuscade, which is unfair to both the trial court and the opposing party" [internal quotation marks omitted] ); State v. Hilton , 45 Conn. App. 207 , 222, 694 A.2d 830 ("[w]e are not bound to consider claims of law not properly raised at trial"), cert. denied, 243 Conn. 925 , 701 A.2d 659 (1997), cert. denied, 522

2018Because confrontation claims that involve testimonial hearsay raise due process concerns, and because those claims are not determined on the basis of the rules of evidence after Crawford v. Washington , 541 U.S. 36 , 61, 124 S.Ct. 1354 , 158 L.Ed. 2d 177 (2004), it is particularly important that trial counsel articulate whether they are raising a constitutional due process claim or an evidentiary issue.

2018Because confrontation claims that involve testimonial hearsay raise due process concerns, and because those claims are not determined on the basis of the rules of evidence after Crawford v. Washington , 541 U.S. 36 , 61, 124 S.Ct. 1354 , 158 L.Ed. 2d 177 (2004), it is particularly important that trial counsel articulate whether they are raising a constitutional due process claim or an evidentiary issue.

2018See, e.g., Chief Disciplinary Counsel v. Rozbicki , 326 Conn. 686 , 695, 167 A.3d 351 (2017) ("to permit a party to raise a claim on appeal that has not been raised at trial-after it is too late for the trial court or the opposing party to address the claim-would encourage trial by ambuscade, which is unfair to both the trial court and the opposing party" [internal quotation marks omitted] ); State v. Hilton , 45 Conn. App. 207 , 222, 694 A.2d 830 ("[w]e are not bound to consider claims of law not properly raised at trial"), cert. denied, 243 Conn. 925 , 701 A.2d 659 (1997), cert. denied, 522

2018See, e.g., Chief Disciplinary Counsel v. Rozbicki , 326 Conn. 686 , 695, 167 A.3d 351 (2017) ("to permit a party to raise a claim on appeal that has not been raised at trial-after it is too late for the trial court or the opposing party to address the claim-would encourage trial by ambuscade, which is unfair to both the trial court and the opposing party" [internal quotation marks omitted] ); State v. Hilton , 45 Conn. App. 207 , 222, 694 A.2d 830 ("[w]e are not bound to consider claims of law not properly raised at trial"), cert. denied, 243 Conn. 925 , 701 A.2d 659 (1997), cert. denied, 522

2018See, e.g., Chief Disciplinary Counsel v. Rozbicki , 326 Conn. 686 , 695, 167 A.3d 351 (2017) ("to permit a party to raise a claim on appeal that has not been raised at trial-after it is too late for the trial court or the opposing party to address the claim-would encourage trial by ambuscade, which is unfair to both the trial court and the opposing party" [internal quotation marks omitted] ); State v. Hilton , 45 Conn. App. 207 , 222, 694 A.2d 830 ("[w]e are not bound to consider claims of law not properly raised at trial"), cert. denied, 243 Conn. 925 , 701 A.2d 659 (1997), cert. denied, 522

2018See, e.g., Chief Disciplinary Counsel v. Rozbicki , 326 Conn. 686 , 695, 167 A.3d 351 (2017) ("to permit a party to raise a claim on appeal that has not been raised at trial-after it is too late for the trial court or the opposing party to address the claim-would encourage trial by ambuscade, which is unfair to both the trial court and the opposing party" [internal quotation marks omitted] ); State v. Hilton , 45 Conn. App. 207 , 222, 694 A.2d 830 ("[w]e are not bound to consider claims of law not properly raised at trial"), cert. denied, 243 Conn. 925 , 701 A.2d 659 (1997), cert. denied, 522

2018As a matter of state evidence law, however, there is no reason to hinder the analysis of eyewitness reliability with purposeless distinctions between suggestiveness and other sources of unreliability." (Citation omitted.) State v. Lawson , supra, 352 Or. at 746 -47 , 291 P.3d 673 .

2018As a matter of state evidence law, however, there is no reason to hinder the analysis of eyewitness reliability with purposeless distinctions between suggestiveness and other sources of unreliability." (Citation omitted.) State v. Lawson , supra, 352 Or. at 746 -47 , 291 P.3d 673 .

2011We therefore do not reach the constitutional due process challenge and need not resolve the thorny question of whether that opinion represented the sort of clarification of the law for which the federal constitution requires collateral relief under Fiore. [13] See In re Shanaira C., 297 Conn. 737, 754 , 1 A.3d 5 (2010) ("we *826 must be mindful that [t]his court has a basic judicial duty to avoid deciding a constitutional issue if a nonconstitutional ground exists that will dispose of the case" [internal quotation marks omitted]); State v. Winot, 294 Conn. 753 , 782 n. 2, 988 A.2d 188 (2010) (

2011We therefore do not reach the constitutional due process challenge and need not resolve the thorny question of whether that opinion represented the sort of clarification of the law for which the federal constitution requires collateral relief under Fiore. [13] See In re Shanaira C., 297 Conn. 737, 754 , 1 A.3d 5 (2010) ("we *826 must be mindful that [t]his court has a basic judicial duty to avoid deciding a constitutional issue if a nonconstitutional ground exists that will dispose of the case" [internal quotation marks omitted]); State v. Winot, 294 Conn. 753 , 782 n. 2, 988 A.2d 188 (2010) (

2011We therefore do not reach the constitutional due process challenge and need not resolve the thorny question of whether that opinion represented the sort of clarification of the law for which the federal constitution requires collateral relief under Fiore. [13] See In re Shanaira C., 297 Conn. 737, 754 , 1 A.3d 5 (2010) ("we *826 must be mindful that [t]his court has a basic judicial duty to avoid deciding a constitutional issue if a nonconstitutional ground exists that will dispose of the case" [internal quotation marks omitted]); State v. Winot, 294 Conn. 753 , 782 n. 2, 988 A.2d 188 (2010) (

2011We therefore do not reach the constitutional due process challenge and need not resolve the thorny question of whether that opinion represented the sort of clarification of the law for which the federal constitution requires collateral relief under Fiore. [13] See In re Shanaira C., 297 Conn. 737, 754 , 1 A.3d 5 (2010) ("we *826 must be mindful that [t]his court has a basic judicial duty to avoid deciding a constitutional issue if a nonconstitutional ground exists that will dispose of the case" [internal quotation marks omitted]); State v. Winot, 294 Conn. 753 , 782 n. 2, 988 A.2d 188 (2010) (

2010The respondent, who is the father of the three children involved in this termination of parental rights case, Giovanni C., Wesley C., and Ravan, C., appeals from the judgments of the trial court terminating his parental rights as to the three children. * 1 The *278 respondent’s sole claim on appeal is that the burden of persuasion by clear and convincing evidence as used in Connecticut and as applied by the trial court in this case “does not meet the requirements of the constitutional due process clause of the fourteenth amendment required by the United States constitution as set forth by the

2010The respondent, who is the father of the three children involved in this termination of parental rights case, Giovanni C., Wesley C., and Ravan, C., appeals from the judgments of the trial court terminating his parental rights as to the three children. * 1 The *278 respondent’s sole claim on appeal is that the burden of persuasion by clear and convincing evidence as used in Connecticut and as applied by the trial court in this case “does not meet the requirements of the constitutional due process clause of the fourteenth amendment required by the United States constitution as set forth by the

2010Ed. 2d 599 (1982).” More specifically, the respondent contends that Connecticut’s formulation of the clear and convincing evidence standard falls short of federal constitutional requirements because it does not contain language similar to that used by the United States Supreme Court in describing the standard in Cruzan v. Director, Missouri Dept. of Health, 497 U.S. 261 , 110 S. Ct. 2841 , 111 L.

2010Ed. 2d 599 (1982).” More specifically, the respondent contends that Connecticut’s formulation of the clear and convincing evidence standard falls short of federal constitutional requirements because it does not contain language similar to that used by the United States Supreme Court in describing the standard in Cruzan v. Director, Missouri Dept. of Health, 497 U.S. 261 , 110 S. Ct. 2841 , 111 L.

2007By requiring that individuals have fair warning that a particular activity may subject [them] to the jurisdiction of a foreign sovereign . . . the [d]ue [p]rocess [c]lause gives a degree of predictability to the legal system that allows potential defendants to structure their primary conduct with some minimum assurance *524 as to where that conduct will and will not render them liable to suit . . . .” (Citations omitted; internal quotation marks omitted.) Burger King Corp. v. Rudzewicz, 471 U.S. 462, 471-72 , 105 S. Ct. 2174 , 85 L.

2007By requiring that individuals have fair warning that a particular activity may subject [them] to the jurisdiction of a foreign sovereign . . . the [d]ue [p]rocess [c]lause gives a degree of predictability to the legal system that allows potential defendants to structure their primary conduct with some minimum assurance *524 as to where that conduct will and will not render them liable to suit . . . .” (Citations omitted; internal quotation marks omitted.) Burger King Corp. v. Rudzewicz, 471 U.S. 462, 471-72 , 105 S. Ct. 2174 , 85 L.

2007“The sixth amendment to the United States constitution . . . guarantee^] a criminal defendant the right to be informed of the nature and cause of the charges against him with sufficient precision to enable him to meet them at trial. . . . [That] the offense should be described with sufficient definiteness and particularity to apprise the accused of the nature of the charge so he can prepare to meet it at his trial . . . are principles of constitutional law [that] are inveterate and sacrosanct.” (Citation omitted; internal quotation marks omitted.) State v. Vumback, 263 Conn. 215, 221-22 , 819

2007“The sixth amendment to the United States constitution . . . guarantee^] a criminal defendant the right to be informed of the nature and cause of the charges against him with sufficient precision to enable him to meet them at trial. . . . [That] the offense should be described with sufficient definiteness and particularity to apprise the accused of the nature of the charge so he can prepare to meet it at his trial . . . are principles of constitutional law [that] are inveterate and sacrosanct.” (Citation omitted; internal quotation marks omitted.) State v. Vumback, 263 Conn. 215, 221-22 , 819

2005The defendant also posits two alternate grounds for affirming the judgment of the Appellate Court, namely, that: (1) the trial court’s presiding over the hearing and trial was a constitutional due process violation reviewable under State v. Golding, 213 Conn. 233, 239-40 , 567 A.2d 823 (1989); and (2) the February 27, 2002 canvass of the defendant by the trial court, Fischer, J., did not establish that the defendant made a knowing and intelligent waiver of his right to counsel before he proceeded pro se during plea bargaining, the probation violation hearing and the criminal jury trial.

2005The defendant also posits two alternate grounds for affirming the judgment of the Appellate Court, namely, that: (1) the trial court’s presiding over the hearing and trial was a constitutional due process violation reviewable under State v. Golding, 213 Conn. 233, 239-40 , 567 A.2d 823 (1989); and (2) the February 27, 2002 canvass of the defendant by the trial court, Fischer, J., did not establish that the defendant made a knowing and intelligent waiver of his right to counsel before he proceeded pro se during plea bargaining, the probation violation hearing and the criminal jury trial.

2005Santiago v. Commissioner of Correction, 39 Conn. App. 674, 682-83 , 667 A.2d 304 (1995).

2005Santiago v. Commissioner of Correction, 39 Conn. App. 674, 682-83 , 667 A.2d 304 (1995).

1998The constitutional due process requirement encompasses the right to notice and a hearing "at a meaningful time." Armstrong v. Manzo, 380 U.S. 545 , 552 (1965).

1997State v. Uretek, Inc., 207 Conn. 706 , 719 (1988).

1995While there is no fourteenth amendment right for an inmate to receive good time credits, when a state creates a right to good time credits, it is “required by the Due Process Clause to insure that the state-created right is not arbitrarily abrogated.” Wolff v. McDonnell, 418 U.S. 539, 557 , 94 S. Ct. 2963 , 41 L.

1995While there is no fourteenth amendment right for an inmate to receive good time credits, when a state creates a right to good time credits, it is “required by the Due Process Clause to insure that the state-created right is not arbitrarily abrogated.” Wolff v. McDonnell, 418 U.S. 539, 557 , 94 S. Ct. 2963 , 41 L.

1991Bartlett v. Krause, 209 Conn. 352 , 362 , 363 .

1990State v. DeJesus, 194 Conn. 376, 388 , 481 A.2d 1277 (1984); State v. Cor-chado, supra, 660. “ ‘The primary purpose of the charge to the jury is to assist them in applying the law correctly to the facts which they find to be established.’ Velardi v. Selwitz, 165 Conn. 635, 637 , 345 A.2d 527 (1974).” State v. Cooper, 182 Conn. 207, 211 , 438 A.2d 418 (1980).

1990State v. DeJesus, 194 Conn. 376, 388 , 481 A.2d 1277 (1984); State v. Cor-chado, supra, 660. “ ‘The primary purpose of the charge to the jury is to assist them in applying the law correctly to the facts which they find to be established.’ Velardi v. Selwitz, 165 Conn. 635, 637 , 345 A.2d 527 (1974).” State v. Cooper, 182 Conn. 207, 211 , 438 A.2d 418 (1980).

1990State v. DeJesus, 194 Conn. 376, 388 , 481 A.2d 1277 (1984); State v. Cor-chado, supra, 660. “ ‘The primary purpose of the charge to the jury is to assist them in applying the law correctly to the facts which they find to be established.’ Velardi v. Selwitz, 165 Conn. 635, 637 , 345 A.2d 527 (1974).” State v. Cooper, 182 Conn. 207, 211 , 438 A.2d 418 (1980).

1990State v. DeJesus, 194 Conn. 376, 388 , 481 A.2d 1277 (1984); State v. Cor-chado, supra, 660. “ ‘The primary purpose of the charge to the jury is to assist them in applying the law correctly to the facts which they find to be established.’ Velardi v. Selwitz, 165 Conn. 635, 637 , 345 A.2d 527 (1974).” State v. Cooper, 182 Conn. 207, 211 , 438 A.2d 418 (1980).

1990State v. DeJesus, 194 Conn. 376, 388 , 481 A.2d 1277 (1984); State v. Cor-chado, supra, 660. “ ‘The primary purpose of the charge to the jury is to assist them in applying the law correctly to the facts which they find to be established.’ Velardi v. Selwitz, 165 Conn. 635, 637 , 345 A.2d 527 (1974).” State v. Cooper, 182 Conn. 207, 211 , 438 A.2d 418 (1980).

1990State v. DeJesus, 194 Conn. 376, 388 , 481 A.2d 1277 (1984); State v. Cor-chado, supra, 660. “ ‘The primary purpose of the charge to the jury is to assist them in applying the law correctly to the facts which they find to be established.’ Velardi v. Selwitz, 165 Conn. 635, 637 , 345 A.2d 527 (1974).” State v. Cooper, 182 Conn. 207, 211 , 438 A.2d 418 (1980).

1980In Goldberg v. Kelly, 397 U.S. 254 , 90 S. Ct. 1011 , 25 L.

1980In Goldberg v. Kelly, 397 U.S. 254 , 90 S. Ct. 1011 , 25 L.