Justia Connecticut Supreme Court Opinion Summaries

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The court of appeals improperly concluded that a thirty-two delay in the execution of an arrest warrant, where the warrant was executed after the expiration of the limitation period, was reasonable as a matter of law such that the state was under no obligation to present evidence demonstrating that the delay was excusable. Defendant was arrested thirty-two days after the issuance of a warrant for his arrest and thirteen days after the expiration of the applicable five-year statute of limitations for his offense. The trial court denied Defendant’s motion to dismiss the charge on the ground that the prosecution was barred by the statute of limitations because the delay in the execution of the warrant was unreasonable. The Appellate Court affirmed. The Supreme Court reversed, holding that the Appellate Court erred in affirming the trial court’s decision denying Defendant’s motion to dismiss pursuant to State v. Crawford, A.2d 1034 (1987). View "State v. Swebilius" on Justia Law

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The statutory aggrievement principles of Conn. Gen. Stat. 8-8 do not extend to appeals from the decisions of historic district commissions brought pursuant to Conn. Gen. Stat. 7-147i. Plaintiffs appealed from two decisions of the Historic District Commission of the Town of Groton with respect to alterations to a barn located on property owned by Steven and Caroline Young. The trial court denied relief, concluding (1) statutory aggrievement under section 8-8 does not extend to historic district commission appeals brought pursuant to section 7-147i, and (2) Plaintiffs failed to establish that they were classically aggrieved with respect to each of the Commission’s two decisions. The Supreme Court affirmed, holding (1) the trial court properly determined that Plaintiffs were not statutorily aggrieved under section 7-147i and section 8-8(a)(1); and (2) the trial court properly determined that Plaintiffs did not establish classical aggrievement in either appeal. View "Mayer v. Historic District Commission of Town of Groton" on Justia Law

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At issue in this case was whether a conservation restriction on private property was violated by the owner of that property and, if so, whether the remedies ordered by the trial court were proper. The Connecticut Supreme Court agreed with the trial court's interpretation of the conservation restriction and its consequent finding that defendant had violated it in multiple respects, and the court saw no impropriety with respect to the portion of the trial court's judgment awarding plaintiff equitable relief. However, the Connecticut Supreme Court agreed with defendant that the trial court's award of punitive damages was noncompliant with the authorizing provision, General Statutes 52-560a(d), and that its award of attorney's fees, in one respect, was improper. Accordingly, the court affirmed in part and reversed in part. View "Lyme Land Conservation Trust v. Platner" on Justia Law

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The Connecticut Supreme Court affirmed the trial court's decision to uphold the Commissioner's determination denying plaintiffs' request for a refund of estate taxes paid by the estate of the decedent. The court held that the trial court properly rendered summary judgment in favor of the Commissioner because defendant properly included the value of the assets contained within the qualified terminable interest property (QTIP) marital deduction trusts in the decedent's gross estate and levied the estate tax thereupon in accordance with General Statutes 12-391 without violating due process. View "Estate of Brooks v. Commissioner of Revenue Services" on Justia Law
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Principally at issue in this case was defense counsel's obligation to investigate and present mitigating evidence that could reduce a defendant's culpability when the defendant has directed counsel not to present such evidence and has refused to aid in the presentation of such evidence. The Connecticut Supreme Court held that a client's resolute, unambiguous instruction not to present mitigating evidence, if made knowingly and voluntarily, can preclude a showing of prejudice from counsel's failure to investigate mitigating evidence. The court held, largely for the reasons set forth by the habeas court, that this standard was met in the present case. Furthermore, the habeas court properly concluded that petitioner had not established a basis for relief on any of his claims challenging his judgment of conviction, and, in light of intervening changes in the law, petitioner's claims challenging the penalty phase and resulting sentence of death have been rendered moot. View "Breton v. Commissioner of Correction" on Justia Law

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The Supreme Court held that Conn. Gen. Stat. 54-1j(a) does not require the trial court to inquire directly of a defendant as to whether he or she has spoken with counsel about the possible immigration consequences of pleading guilty before the court accepts the defendant’s guilty plea. Accordingly, the Court affirmed the judgment of the trial court, which denied Defendant’s motion to vacate his guilty plea to one count of conspiracy to commit larceny in the third degree on the ground that the trial court failed to ask Defendant whether he had spoken with counsel about the possible immigration consequences of pleading guilty before accepting the plea offer. Because Defendant expressly acknowledged that he understood those consequences, the trial court substantially complied with section 54-1j. View "State v. Lima" on Justia Law

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Petitioner was found guilty in 2002 of the 1975 murder of his neighbor. The habeas court granted Petitioner’s petition seeking a writ of habeas corpus, concluding that Petitioner’s criminal trial counsel was constitutionally ineffective on three grounds. The Supreme Court reversed the habeas court’s judgment, holding (1) the habeas court erred in concluding that Petitioner’s trial counsel was constitutionally ineffective; (2) Petitioner’s alternative grounds for affirming the habeas court’s judgment were unavailing; and (3) the habeas court did not err in rejecting Petitioner’s claim that counsel had a conflict of interest in representing him. Remanded. View "Skakel v. Commissioner of Correction" on Justia Law

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After the bankruptcy court granted Plaintiff a discharge of her debts, Plaintiff filed this action against the named defendants, alleging misuse of funds of a trust established by her mother. Plaintiff subsequently filed a motion to substitute the bankruptcy trustee as the proper plaintiff. The trial court denied the motion, concluding that Plaintiff failed to show that she had brought the action in her own name due to a mistake. The court then dismissed the action for lack of subject matter jurisdiction. While Plaintiff’s appeal was pending, the bankruptcy court granted the bankruptcy trustee’s motion to abandon the underlying cause of action. The Appellate Court affirmed. The Supreme Court dismissed Plaintiff’s appeal as moot, holding that because the bankruptcy trustee abandoned the underlying action and Plaintiff no longer was seeking to substitute the trustee as party plaintiff, resolution of this claim would afford Plaintiff no practical relief. View "Gladstein v. Goldfield" on Justia Law

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In this summary process action, the trial court relied on the “spirit” of certain federal disability laws in support of an equitable defense to the eviction of Defendant, a tenant who kept an “emotional support dog” in her federally subsidized rental apartment despite a clause restricting pets that was included in her lease. Plaintiff appealed from the trial court’s judgment in favor of Defendant. The Supreme Court reversed, holding (1) this appeal was not rendered moot when Plaintiff commenced an ancillary summary process action against Defendant, the filing of which had the effect of affirmatively reinstating Defendant’s tenancy; and (2) the trial court abused its discretion by relying on the spirit of the federal regulations and by applying the doctrine of equitable nonforfeiture to support its equitable decision in favor of Defendant. View "Presidential Village, LLC v. Phillips" on Justia Law

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Plaintiff brought an action against a hospital and one of its employees for personal injuries allegedly sustained as a result of medical malpractice. The jury returned a verdict in favor of the hospital. The trial court ultimately awarded the hospital $5965 in expert fees and other costs. Five months later, the hospital filed a motion to hold Plaintiff in contempt of court, arguing that the award of costs was a court order and thus amenable to contempt and that Plaintiff had not paid any of the award costs. The court denied the hospital’s motion for contempt, concluding that, as a matter of law, it lacked the inherent authority to coerce compliance with an award of costs. The Supreme Court affirmed, holding that, under ordinary circumstances such as those in this case, the court’s inherent contempt power is not an appropriate means of enforcing an award of costs or other monetary judgment. View "Pease v. Charlotte Hungerford Hospital" on Justia Law