Justia Connecticut Supreme Court Opinion Summaries

The defendant was convicted of murder, tampering with or fabricating physical evidence, and making a false statement in connection with the shooting death of his wife. He allegedly staged the crime scene to resemble a home invasion. The defendant appealed, claiming multiple instances of prosecutorial impropriety deprived him of a fair trial.In the lower court, the trial court denied the defendant’s motion to preclude certain evidence and denied in part his motion to suppress certain statements. The trial court also admitted data from the victim’s Fitbit after a Porter hearing, finding the evidence scientifically reliable. The jury found the defendant guilty on all counts, and the trial court sentenced him to sixty-five years of imprisonment.The Connecticut Supreme Court reviewed the case and found four instances of prosecutorial impropriety: (1) the prosecutor’s failure to rephrase a question about a "mini Cheshire scene," (2) asking the defendant if he planned to kill the victim during a trip to Vermont, (3) stating that the defendant was counting on the jury to be gullible, lazy, and unintelligent, and (4) failing to disclose an expert witness’s anticipated testimony. However, the court concluded that these improprieties did not deprive the defendant of a fair trial, either individually or collectively.The court also held that the trial court did not abuse its discretion in admitting the Fitbit data, as the evidence was scientifically reliable. Additionally, the court found that the defendant was not in custody during his hospital interview for purposes of Miranda, and thus, the trial court properly denied the motion to suppress his statement.The Connecticut Supreme Court affirmed the judgment of the trial court. View "State v. Dabate" on Justia Law

The plaintiffs, two grandchildren and a friend of the decedent, Wisniewski, filed a lawsuit against the defendant attorney, alleging professional negligence and breach of contract in the preparation of Wisniewski's will. They claimed that Wisniewski intended for his TD Ameritrade account to be distributed equally among five individuals, including the plaintiffs, but due to the defendant's failure to ensure the account's beneficiary designation was changed, the entire account was distributed to Wisniewski's daughter, the sole designated beneficiary.The trial court dismissed the professional negligence claim, ruling that the plaintiffs lacked standing because Connecticut law only allows third-party beneficiaries to sue attorneys for errors in drafting or executing a will, not for failing to change a beneficiary designation. The court later dismissed the breach of contract claim, finding it functionally identical to the dismissed negligence claim.The Connecticut Supreme Court reviewed the case. It agreed with the trial court that the plaintiffs did not allege a drafting error in the will. However, it concluded that public policy supports holding attorneys liable for failing to advise clients about the need to change beneficiary designations to effectuate their estate plans. The court held that the plaintiffs had standing to sue for professional negligence based on the defendant's failure to advise Wisniewski about the implications of the beneficiary designation on his estate plan. The court did not recognize a duty for attorneys to ensure that clients actually change beneficiary designations.The court affirmed the dismissal of the breach of contract claim, agreeing that the allegations did not sound in breach of contract but were essentially the same as the dismissed negligence claim. The case was remanded for further proceedings on the professional negligence claim related to the failure to advise. View "Wisniewski v. Palermino" on Justia Law

The defendant was convicted of assault in the first degree for stabbing the victim. The key facts of the case include the defendant and the victim having a history of domestic violence, with the defendant previously assaulting the victim. On the day of the incident, the victim was stabbed multiple times while entering her home. The victim identified the defendant as her attacker, and the police arrested him based on this identification and other circumstantial evidence.The trial court admitted evidence of two prior incidents where the defendant had physically assaulted the victim to establish his specific intent to cause serious bodily injury. The defendant objected, arguing that the evidence was irrelevant and highly prejudicial. The trial court allowed the evidence, and the jury found the defendant guilty. The defendant appealed, claiming that the trial court abused its discretion in admitting the prior misconduct evidence.The Appellate Court affirmed the trial court's decision, concluding that the prior misconduct evidence was relevant to the defendant's intent and that its probative value outweighed its prejudicial effect. The court also found that any error in admitting the evidence was harmless given the strength of the state's case and the limiting instructions provided to the jury.The Supreme Court of Connecticut reversed the Appellate Court's judgment, holding that the trial court abused its discretion in admitting the prior misconduct evidence. The court found that the probative value of the evidence did not outweigh its prejudicial effect, as the key issue at trial was the identity of the attacker, not the intent. The court also determined that the admission of the prior misconduct evidence was harmful because it presupposed the defendant's identity as the attacker and the remaining evidence was equivocal. The case was remanded for a new trial. View "State v. Marcello E." on Justia Law

The defendant was convicted of murder in connection with the shooting death of the victim. The victim was shot while talking to her boyfriend outside her apartment building. The defendant, along with two other individuals, fired several shots toward the victim’s residence, and one bullet struck the victim in the head, causing her death. The initial investigation did not result in charges, but years later, new information from witnesses led to the defendant’s arrest.The Superior Court in the judicial district of Hartford tried the case, and the jury found the defendant guilty of murder. The defendant appealed, claiming that the trial court improperly admitted evidence of his alleged gang affiliation and his actions after law enforcement attempted to arrest him. The trial court had allowed the gang affiliation evidence to establish a motive for the shooting and admitted evidence of the defendant’s evasive conduct as indicative of his consciousness of guilt.The Supreme Court of Connecticut reviewed the case and held that the trial court did not abuse its discretion in admitting the gang affiliation evidence, as it was relevant to establishing a motive for the shooting and its probative value outweighed any unfair prejudicial impact. The court also found that the trial court properly admitted evidence of the defendant’s evasive conduct after law enforcement attempted to arrest him, as it was probative of the defendant’s consciousness of guilt. The court affirmed the judgment of the trial court. View "State v. Jones" on Justia Law

The complainant, John Ward, filed a complaint with the Commission on Human Rights and Opportunities (CHRO) alleging that the City of Stamford discriminated against him based on his veteran status and disability. The CHRO found reasonable cause and certified the complaint to the Office of Public Hearings (OPH). During the public hearing, Ward moved to amend his complaint to include a claim for denial of reasonable accommodations. The human rights referee granted the motion over the city's objection.The city filed an interlocutory administrative appeal with the Superior Court, arguing that the CHRO lacked jurisdiction to hear the amended complaint without a reasonable cause finding. The CHRO and Ward moved to dismiss the appeal, contending that interlocutory rulings are not appealable under General Statutes § 46a-94a (a) and that the statutory requirements for an interlocutory appeal under § 4-183 (b) were not met. The trial court denied the motions to dismiss, finding that the referee's ruling was a final decision under § 4-183 (a).The Supreme Court of Connecticut reviewed the case and concluded that the referee's ruling was not a final decision under § 4-183 (a) because it did not terminate any aspect of the case or determine any rights or obligations. The court also determined that § 46a-94a (a) allows for interlocutory appeals under § 4-183 (b), but the city's appeal did not meet the criteria for such an appeal because postponement would not result in an inadequate remedy. The court reversed the trial court's decision and remanded with direction to grant the motions to dismiss the city's appeal. View "Stamford v. Commission on Human Rights& Opportunities" on Justia Law

The plaintiffs sought to recover damages from the defendants for alleged violations of the Connecticut Product Liability Act (CPLA) after their minor child, L.L., was severely injured. The injury occurred when a Graco car seat, placed on a kitchen counter next to an electric range stove, caught fire. The plaintiffs claimed that the car seat and stove were defectively designed or manufactured. As a result of the fire, L.L. suffered severe burns and injuries. The plaintiffs, including L.L.'s parents, also sought damages for loss of filial consortium, alleging that they lost the society, care, and companionship of their daughter due to her injuries.The United States District Court for the District of Connecticut reviewed the case and certified a question to the Connecticut Supreme Court, asking whether Connecticut law recognizes a parent's claim for loss of filial consortium when a minor child suffers severe but nonfatal injuries due to a defendant's tortious conduct. The District Court had previously denied the defendants' motion to dismiss the loss of consortium claims without prejudice.The Connecticut Supreme Court concluded that Connecticut law does not recognize a cause of action for loss of filial consortium. The court reasoned that the justifications for recognizing loss of spousal and parental consortium claims, which are based on mutual dependence and reliance, do not apply to the parent-child relationship in the same way. The court emphasized that the emotional distress experienced by a parent due to a child's severe injury is distinct from the relational loss addressed by loss of consortium claims. The court found the reasoning of jurisdictions that distinguish between parental and filial consortium more persuasive and declined to expand the scope of liability to include loss of filial consortium. View "L. L. v. Newell Brands, Inc." on Justia Law

The case involves the defendant, who was convicted of multiple counts of sexual assault in the first degree and risk of injury to a child. The victims, D and T, were sexually abused by the defendant, who was in a relationship with their mother, Q, and lived with them for several years. The abuse began when the victims were five years old and continued until they were eleven. The victims disclosed the abuse to their mother years later, which led to the defendant's arrest and trial.In the trial court, the defendant was found guilty on five counts of sexual assault in the first degree and eight counts of risk of injury to a child. The trial court instructed the jury, based on the precedent set in State v. Daniel W. E., that the victims' delay in reporting the abuse should not be considered when evaluating their credibility. The defendant appealed, arguing that this instruction violated his due process rights and that the trial court abused its discretion by allowing certain testimony from D.The Supreme Court of Connecticut reviewed the case and overruled the portion of Daniel W. E. that modified the constancy of accusation doctrine. The court returned to the standard set in State v. Troupe, which allows constancy evidence to corroborate the victim's testimony but not for substantive purposes, and permits the jury to consider the victim's delay in reporting when evaluating credibility. The court concluded that the trial court's instruction was erroneous but harmless, as it was not reasonably probable that the instruction misled the jury.Additionally, the court held that the trial court did not abuse its discretion in allowing D to testify that the defendant told her he played the same sexual "games" with his daughter, as this testimony was probative of the defendant's grooming behavior. The judgment of the trial court was affirmed. View "State v. Adam P." on Justia Law

The plaintiff law firm sought to recover damages from the defendant, a former client, for breach of contract in federal court. The defendant had engaged the plaintiff to represent it in a litigation matter but failed to pay the agreed-upon legal fees. The plaintiff claimed that the defendant's breach was wilful and malicious, and sought common-law punitive damages in addition to compensatory damages.The United States District Court for the District of Connecticut partially granted the plaintiff's motion for summary judgment on the breach of contract claim, awarding compensatory damages. However, the court found genuine issues of material fact regarding the plaintiff's claim for punitive damages and the defendant's counterclaims, including legal malpractice. The jury later found in favor of the plaintiff on all claims and counterclaims, determining that the defendant's breach was wilful and malicious. The District Court then certified a question to the Connecticut Supreme Court regarding the recoverability of common-law punitive damages for wilful and malicious breach of contract.The Connecticut Supreme Court concluded that a law firm may not recover common-law punitive damages for a client's breach of contract unless it pleads and proves the existence of an independent tort for which punitive damages are recoverable. The court noted that Connecticut appellate courts generally do not allow punitive damages for breach of contract claims, except in certain contexts like insurance and surety. The court emphasized the different purposes of compensatory damages in contract law and punitive damages in tort law, and declined to adopt a broader rule permitting punitive damages for wilful, malicious, or reckless breaches of contract. The court's decision aligns with the majority rule in other jurisdictions and the Restatements of Contracts and Torts. View "McCarter & English, LLP v. Jarrow Formulas, Inc." on Justia Law

The plaintiffs, property owners in Danbury, Connecticut, challenged the tax assessments on their properties, each valued at over one million dollars, by appealing to the Superior Court. They were required by statute to file appraisals of their properties within 120 days of filing their appeals. The plaintiffs requested extensions to this deadline, which the court granted. However, they failed to file the appraisals with the court by the extended deadlines, although they did provide the appraisals to the defendant's counsel.The trial court initially dismissed five of the six tax appeals for failure to meet the filing deadline, concluding it lacked subject matter jurisdiction. The court later granted the plaintiffs' motions to open the judgments of dismissal and for reargument, citing similar cases where the court had not dismissed appeals under similar circumstances. The court denied the defendant's corrected motion to dismiss the sixth appeal, finding no prejudice to the defendant from the late filing.The defendant appealed to the Connecticut Supreme Court, arguing that the trial court lacked subject matter jurisdiction due to the plaintiffs' failure to timely file the appraisals. The plaintiffs contended that the appeal was moot because they had filed new tax appeals under a recent statutory amendment allowing for such actions if previous appeals were dismissed under certain conditions.The Connecticut Supreme Court held that the appeal was not moot, as the underlying appeals were not "dismissed" for purposes of the new statutory provision, given that the judgments of dismissal had been opened. The court further held that the appraisal filing requirement in § 12-117a (a) (2) is not subject matter jurisdictional. The requirement is mandatory but arises after the commencement of a tax appeal, and the time period for filing the appraisal can be extended by the court for good cause. The judgments of the Superior Court were affirmed. View "7 Germantown Road, LLC v. Danbury" on Justia Law

The defendant was convicted of the murder of her minor son, E, and arson in the second degree. The case arose from an incident where the defendant sedated E with a substantial amount of diphenhydramine, set two fires in their home, and was found unconscious alongside E, who was later pronounced dead. The medical examiner determined E's cause of death to be homicidal asphyxia, with diphenhydramine intoxication as a contributing factor. The defendant's social media posts prior to the incident indicated distress and potential premeditation.The trial court, after a competency hearing, found the defendant competent to stand trial. The jury found the defendant guilty of both charges. The defendant appealed, claiming her amnesia deprived her of a fair trial, the trial court improperly admitted social media posts, and the evidence was insufficient to support her convictions.The Connecticut Supreme Court reviewed the case. It held that the defendant's claim of amnesia affecting her right to a fair trial failed under the first prong of State v. Golding because she did not request a posttrial determination regarding the fairness of the trial, making the record inadequate for review. The court also found that the trial court did not abuse its discretion in admitting the social media posts, as they were properly authenticated through testimony.Regarding the sufficiency of the evidence, the court concluded that the evidence was sufficient to support the defendant's conviction of murder. The jury could reasonably find that the defendant caused E's death with intent, based on the cumulative evidence, including the circumstances of the fire, the sedative found in E's system, and the defendant's behavior and social media posts. The evidence was also sufficient to support the arson conviction, as the jury could reasonably find that the defendant set the fires with the intent to damage the home and conceal the murder. The court affirmed the judgment. View "State v. Ziolkowski" on Justia Law