State of Connecticut v. Todd Rizzo

Summary

The court upheld the defendant’s death sentence after rejecting challenges to his waiver of a sentencing jury, the participation of a judge in the three-judge panel, the vagueness of the heinous-cruel-or-depraved aggravating factor, and the evidentiary support for that factor. It concluded that the jury waiver was knowing, voluntary, and intelligent; that the judge’s prior involvement did not establish unconstitutional bias or plain error; that the aggravating-factor construction adequately limited sentencing discretion; and that substantial evidence supported the panel’s findings. Justice Zarella concurred while reserving concerns about the state constitutional analysis framework.