Justia Connecticut Supreme Court Opinion Summaries

The case involves a dispute between divorced parents over the custody and visitation rights of their minor children. The plaintiff father was granted sole legal custody of the children, while the defendant mother was given limited visitation rights. The trial court's order allowed the plaintiff to unilaterally suspend the defendant's visitation with their son, R, if he reasonably determined, after consulting with R's therapist, that the visits were causing negative behavioral or emotional consequences for R.The trial court initially granted the plaintiff's motion to modify custody, awarding him sole legal custody and primary physical custody of the children. The court found that the defendant's behavior, including her mistrust and denigration of the plaintiff, negatively impacted the children. The court's order allowed the defendant to have supervised visits with R, which could become unsupervised if the plaintiff approved. However, the plaintiff was also given the authority to suspend the defendant's visitation if he believed it was harming R.The Connecticut Supreme Court reviewed the case and concluded that the trial court's order improperly delegated judicial authority to the plaintiff. The court held that a trial court cannot delegate its statutory duty to decide custody and visitation matters to a nonjudicial entity, including a parent. The court emphasized that only the trial court has the authority to modify visitation orders and that delegating this authority to a parent creates a situation ripe for abuse and misjudgment. The court reversed the trial court's order to the extent that it allowed the plaintiff to unilaterally suspend the defendant's visitation rights and remanded the case for further proceedings on this issue. View "R. H. v. M. H." on Justia Law

The defendant was convicted of multiple counts of sexual assault and risk of injury to a child based on allegations of sexual abuse involving his children, B, J, and D. The charges included sexual assault in the first degree, sexual assault in the fourth degree, and risk of injury to a child. The defendant appealed, arguing insufficient evidence, statute of limitations issues, improper admission of sexual misconduct evidence, and violations of his confrontation rights.The trial court joined the cases for trial, and the jury found the defendant guilty on all counts. The trial court vacated some convictions as lesser included offenses and sentenced the defendant to a total effective term of twenty-five years, suspended after fifteen years, followed by twenty years of probation.On appeal, the Connecticut Supreme Court found insufficient evidence to support the defendant’s conviction of sexual assault in the first degree and the vacated conviction of sexual assault in the fourth degree involving J. The court noted that the state failed to prove that the defendant touched J’s genitals with his mouth, lips, or tongue, a necessary element for these charges.The court also agreed with the defendant that his convictions of sexual assault in the first degree and risk of injury to a child involving B should be reversed under the plain error doctrine. The trial court failed to obtain the defendant’s knowing and voluntary waiver of the statute of limitations, which had expired before the charges were filed.The court rejected the defendant’s claims regarding the improper admission of sexual misconduct evidence and found that the trial court did not abuse its discretion in admitting this evidence. The court also found no error in the trial court’s decision not to conduct an in camera review of J’s and B’s psychiatric records and in declining to release D’s psychiatric records.The Connecticut Supreme Court reversed the convictions related to B and the conviction of sexual assault in the first degree related to J, remanding the case for resentencing on the remaining convictions. The judgments were affirmed in all other respects. View "State v. Daren Y." on Justia Law

The defendant was convicted of murder and criminal possession of a firearm. The case involved the shooting of the victim, Derrick Nichols, who was found dead near the defendant's vehicle. An eyewitness, Sheleese Lockhart, testified that she saw the victim being shot from inside the defendant's car. The police recovered several items belonging to the victim and shell casings from the crime scene. Gunshot residue tests on the defendant's hands, clothing, and car revealed particles consistent with gunshot residue.The trial court admitted the gunshot residue evidence and allowed expert testimony on the matter. However, it precluded the defendant's expert from testifying about surveillance footage that the defense argued showed the victim walking outside the car before being shot, contradicting the eyewitness testimony. The trial court applied the standard for nonpercipient witness identification rather than the standard for expert testimony.The Connecticut Supreme Court reviewed the case. It held that the evidence was sufficient to support the jury's verdict, as the physical evidence did not render the state's theory of the case a physical impossibility. The court found that the trial court improperly applied the wrong standard in precluding the defendant's expert testimony about the surveillance footage. This error was not harmless because the expert's testimony could have challenged the credibility of the state's key eyewitness. Therefore, the court reversed the judgment of conviction and remanded the case for a new trial.The court also addressed the admissibility of the gunshot residue evidence, concluding that the trial court did not abuse its discretion in admitting expert testimony that one and two element particles consistent with gunshot residue were found on the defendant and in his vehicle. The probative value of this evidence was not outweighed by the danger of unfair prejudice. View "State v. Williams" on Justia Law

The case involves a dispute between a property owner and a city regarding the validity of a lien placed on the property. The property, an apartment building, was destroyed by arson, leading to the displacement of its tenants. The city incurred costs relocating the tenants and placed a lien on the property to recover these expenses under the Uniform Relocation Assistance Act (URAA).The trial court ruled in favor of the property owner, determining that the lien was invalid because the displacement was caused by a third party's arson, not by the city's enforcement of its building code. The court allowed the property owner to challenge the lien using an affirmative defense provided by the URAA, which is typically available only in civil actions brought by a municipality to recover relocation expenses.The Supreme Court of Connecticut reviewed the case and reversed the trial court's decision. The Supreme Court held that the tenants were "displaced persons" under the URAA because their displacement was a direct result of the city's enforcement of its building code, regardless of the arson being the initial cause. The court further held that the affirmative defense provided by the URAA, which allows a landlord to argue that the displacement was not due to their violation of housing codes, is only available in civil actions brought by the municipality and cannot be used to challenge a lien in an application to discharge it.The Supreme Court directed the trial court to deny the property owner's application to discharge the city's lien, thereby upholding the city's right to recover its relocation expenses through the lien. View "PPC Realty, LLC v. Hartford" on Justia Law

The defendant was convicted of murder as an accessory and conspiracy to commit murder. She waived her right to a jury trial and opted for a trial by a three-judge panel. The defendant argued that the evidence was insufficient to support her conviction and that her waiver of a jury trial was not made knowingly, intelligently, and voluntarily because the canvassing court failed to explain that the three-judge panel did not need to be unanimous to convict. Additionally, she claimed that the panel improperly began deliberations before the close of evidence.The trial court found the defendant guilty based on evidence including her tumultuous relationship with the victim, her presence near the crime scene, and her inconsistent statements to the police. The defendant had initially claimed she was at home during the shooting but later admitted to being picked up by her cousin near the scene. Phone records also showed she contacted her cousin multiple times shortly before the murder.The Connecticut Supreme Court held that the evidence was sufficient to support the defendant’s conviction. The court noted that the defendant’s presence at the scene, her actions during the crime, and her inconsistent statements provided a reasonable basis for the panel’s verdict.However, the court invoked its supervisory authority to require that trial courts must specifically advise defendants who waive their right to a jury trial in favor of a three-judge panel that only two of the three judges need to agree to convict, unlike a jury which must be unanimous. The court concluded that this new rule should apply to the defendant’s case, reversed her conviction, and ordered a new trial.The court also addressed the defendant’s claim regarding premature deliberations by the panel, concluding that unlike juries, three-judge panels are not constitutionally prohibited from discussing the case before the close of evidence. View "State v. King" on Justia Law

The defendant was convicted of murder, carrying a pistol without a permit, and criminal possession of a firearm. The case involved the shooting of the victim, Giovanni Rodriguez, in a hotel parking lot. The defendant, Trevor Monroe Outlaw, was identified as the shooter by his girlfriend, Cheenisa Rivera, who testified against him under a cooperation agreement. Rivera and another witness, Loretta Martin, were both in witness protection and testified that the defendant was in the car from which the shots were fired.The trial court denied the defendant's motion to preclude evidence of Rivera's plea agreement, which included her guilty plea to conspiracy to commit murder. The jury found the defendant guilty of murder and carrying a pistol without a permit, and the court found him guilty of criminal possession of a firearm. The defendant appealed, arguing that the trial court erred by not questioning or dismissing a juror who appeared to be sleeping, improperly admitted evidence related to witness protection, allowed Rivera to testify about her guilty plea, and that the prosecutor's comments during closing arguments violated his right to a jury trial.The Connecticut Supreme Court held that the trial court's limited inquiry into the allegedly sleeping juror was adequate and did not deprive the defendant of a fair trial. The court also found that although the trial court improperly admitted evidence related to witness protection, the defendant did not demonstrate that this resulted in a manifest injustice. The admission of Rivera's guilty plea was deemed harmless, as it did not substantially impact the jury's verdict. Finally, the court concluded that the prosecutor's remarks during closing arguments did not violate the defendant's right to a jury trial, as they were intended to bolster Rivera's credibility rather than criticize the defendant's decision to go to trial. The judgment of the trial court was affirmed. View "State v. Outlaw" on Justia Law

The case involves a plaintiff, the surviving spouse of a decedent who was employed by the Stamford Police Department. The decedent sustained injuries that led to a significant loss of vision, and he received total incapacity benefits under Connecticut General Statutes § 31-307 (c) due to his permanent and total loss of sight. The plaintiff sought permanent partial disability benefits under § 31-308 (b) after the decedent's death, arguing that his entitlement to these benefits had vested during his lifetime.The administrative law judge denied the plaintiff's claim for permanent partial disability benefits, concluding that although the decedent's condition was permanent, the defendants were entitled to a credit for the total incapacity benefits already paid, which exceeded the amount of the claimed permanency benefits. The Compensation Review Board affirmed this decision, stating that the decedent had not reached maximum medical improvement during his lifetime, a necessary condition for the vesting of permanency benefits under § 31-308 (b).The Supreme Court of Connecticut reviewed the case and affirmed the decision of the Compensation Review Board. The court held that a finding of a permanent injury under § 31-307 (c) does not automatically entitle a claimant to permanency benefits under § 31-308 (b) without a specific finding of maximum medical improvement or an agreement between the parties establishing such a finding. The court concluded that the record did not establish that the decedent had reached maximum medical improvement during his lifetime, and therefore, his entitlement to permanency benefits did not vest before his death. View "Esposito v. Stamford" on Justia Law

The plaintiff, an employee, alleged that her employer created a hostile work environment through the actions of her immediate superior, who made racially discriminatory comments. The plaintiff reported these incidents to the employer's human resources department, which conducted an investigation and issued a one-day suspension to the superior. Despite the employer's actions, the plaintiff felt unable to continue working under the superior and transferred to another division.The Commission on Human Rights and Opportunities determined that the employer was not vicariously liable for the hostile work environment because the superior did not have the authority to take tangible employment actions against the plaintiff. The trial court upheld this decision, and the Appellate Court affirmed, applying the definition of "supervisor" from the U.S. Supreme Court's decision in Vance v. Ball State University, which limits the term to those who can take tangible employment actions.The Connecticut Supreme Court reviewed the case and affirmed the Appellate Court's decision. The court held that the Vance definition of "supervisor" applies to claims under the Connecticut Fair Employment Practices Act. Since the superior did not have the authority to take tangible employment actions against the plaintiff, the employer could not be held vicariously liable for the creation of a hostile work environment. The court emphasized the importance of consistency with federal law in interpreting state employment discrimination statutes. View "O'Reggio v. Commission on Human Rights & Opportunities" on Justia Law

The case involves two competing slates of candidates seeking to appear on the ballot for the March 5, 2024, primary election for the Democratic Town Committee for the seventh district of Hartford. The plaintiffs, members of one slate, challenged the validity of a petition sheet submitted by the defendants, members of the other slate, on the grounds that one signature was not signed by the named individual but by his son under a purported power of attorney. The defendants counterclaimed, arguing that five petition sheets submitted by the plaintiffs should be invalidated for not including a written tally of the number of verified signatures as required by statute.The Superior Court in the judicial district of Hartford found that the signature in question on the defendants' petition sheet was invalid because there was no evidence that the son had a valid power of attorney or that it included the authority to sign political petitions. Consequently, the court rejected the entire petition sheet, reducing the defendants' valid signatures below the required threshold, and ordered their removal from the ballot. The court also found that one of the plaintiffs' petition sheets contained a forged signature and rejected it, but it ruled that the other five challenged sheets substantially complied with the statutory requirements despite lacking the signature tally.The Connecticut Supreme Court reviewed the case and agreed with the trial court that the signature on the defendants' petition sheet was invalid and that the entire sheet must be rejected. The court held that the statutory language was clear in requiring the rejection of any petition page with procedural violations, including false attestations. However, the Supreme Court disagreed with the trial court's finding of substantial compliance for the plaintiffs' five petition sheets lacking the required tally. The court held that these sheets must also be rejected, which would reduce the plaintiffs' valid signatures below the required threshold, disqualifying both slates from the primary ballot.The judgment was reversed in part and affirmed in part, with the case remanded for further proceedings to determine the conduct of the primary election with both slates disqualified. View "Airey v. Feliciano" on Justia Law

The plaintiffs, parents of minor children, challenged a public act that eliminated the religious exemption from vaccination requirements for school enrollment. They argued that the act violated their constitutional rights to free exercise of religion, equal protection, and a free public education, as well as their statutory rights under Connecticut law. The defendants, state and municipal officials, moved to dismiss the case on the grounds of sovereign immunity.The trial court denied the defendants' motions to dismiss, concluding that the plaintiffs' constitutional claims satisfied the substantial claim exception to sovereign immunity, and their statutory claim under Connecticut law satisfied the statutory waiver exception. The defendants appealed this decision.The Connecticut Supreme Court reviewed the case and determined that the trial court must assess the legal sufficiency of the plaintiffs' allegations to determine whether they have asserted a substantial claim of a constitutional violation. The court concluded that the plaintiffs' constitutional claims failed as a matter of law. The act was deemed a neutral law of general applicability, rationally related to the state's interest in protecting public health. The court also found that the act did not violate the plaintiffs' right to a free public education, as it imposed a reasonable vaccination requirement.However, the court agreed with the trial court that the plaintiffs' statutory free exercise claim under Connecticut law satisfied the statutory waiver exception to sovereign immunity. The court found that the scope of the waiver extended to free exercise challenges to the enforcement of legislation and that applying the statute to the public act did not violate any constitutional principles.The Connecticut Supreme Court reversed the trial court's decision in part, directing the dismissal of the constitutional claims, but affirmed the decision regarding the statutory claim, allowing it to proceed. View "Spillane v. Lamont" on Justia Law