Justia Connecticut Supreme Court Opinion Summaries

The plaintiffs, former residents of a federally subsidized housing complex, alleged that the defendants, the complex's owner and management company, failed to maintain the property in a safe and habitable condition. They claimed the defendants delayed inspections, concealed hazards, and violated housing laws. The plaintiffs sought class certification for all residents from 2004 to 2019, citing issues like a 2019 sewage backup and systemic neglect.The Superior Court in Hartford, transferred to the Complex Litigation Docket, denied the motion for class certification. The court found that the proposed class did not meet the predominance and superiority requirements under Practice Book § 9-8 (3). It reasoned that determining whether each unit was uninhabitable required individualized proof, making a class action unsuitable. The court noted that while some claims might support class certification for specific events, the broad class definition over many years was too extensive.The Connecticut Supreme Court reviewed the case and affirmed the lower court's decision. The court held that the proposed class was too broad and lacked generalized evidence for the entire period. It emphasized that the trial court had no obligation to redefine the class sua sponte. The plaintiffs did not request a narrower class definition, and the trial court was not required to do so on its own. The court concluded that the trial court did not abuse its discretion in denying class certification. View "Collier v. Adar Hartford Realty, LLC" on Justia Law

In September 1995, the body of a young woman, later identified as the defendant's daughter, was found in New Britain, Connecticut. The body was wrapped in trash bags and sleeping bags, and the police collected hairs and palm prints from the scene. Around the same time, the defendant told a family member he was leaving the country for a job and that his wife and daughter had already left. In October 1995, the body of the defendant's wife was found in Massachusetts. Both were reported missing later that year. In 2014, law enforcement collected DNA and prints from the defendant, linking him to the crime scene. The defendant was convicted of his wife's murder in Massachusetts and later charged with his daughter's murder in Connecticut.The trial court denied the defendant's motion to dismiss for lack of territorial jurisdiction, applying a presumption that the murder occurred where the body was found. The court also denied the defendant's request for a jury instruction that his palm prints on the trash bags could not establish his connection to the crime unless they were impressed at the time of the crime. The jury found the defendant guilty, and he was sentenced to sixty years in prison.The Connecticut Supreme Court affirmed the trial court's decision. The court held that the presumption that a murder occurred where the body was found was valid and did not violate due process. The court also found sufficient evidence to establish the defendant's identity as the murderer, including consciousness of guilt evidence and physical evidence linking him to the crime scene. The court further held that the trial court properly declined to provide the requested jury instruction on fingerprint evidence, as the palm prints were not the only or principal evidence against the defendant. View "State v. Honsch" on Justia Law

The plaintiff landlord initiated a summary process action to evict the defendant tenant from an apartment. The trial court ruled in favor of the defendant, who then sought attorney’s fees under a statute that allows consumers to recover such fees when a contract includes a unilateral attorney’s fees provision favoring the commercial party. The lease agreement in question capped the plaintiff’s recoverable attorney’s fees at $750. The trial court awarded the defendant $3500 in attorney’s fees, reasoning that limiting the defendant’s recovery to $750 would not achieve true parity between the parties, as intended by the statute.The plaintiff appealed, arguing that the trial court could only award the defendant up to $750 in attorney’s fees, as specified in the lease agreement. The plaintiff contended that the statute required the court to base the defendant’s award on the same terms governing the plaintiff’s fees, as long as it was practicable to do so.The Connecticut Supreme Court reviewed the case and concluded that trial courts have discretion to award a prevailing consumer reasonable attorney’s fees in excess of the contractual cap when it is not practicable to base the award on the contractual terms. The court determined that the term "practicable" means feasible under the circumstances, which are circumstances that achieve equity or fairness. The court emphasized that the equitable purpose of the statute is to rectify the imbalance of power between consumers and commercial parties in contract disputes.The court vacated the trial court’s award of $3500 in attorney’s fees and remanded the case for a new hearing. The trial court was directed to determine whether it was practicable to base the defendant’s award on the lease agreement’s terms and, if not, to award reasonable attorney’s fees consistent with the statute’s equitable purpose. View "Centrix Management Co., LLC v. Fosberg" on Justia Law

In 1990, the petitioner was convicted of murder, largely based on two cross-racial eyewitness identifications. Both witnesses initially identified another person as the shooter but later identified the petitioner, who was the only Black man at the defense table during a probable cause hearing. The petitioner challenged the identification procedures and jury instructions on appeal, but the Connecticut Supreme Court upheld his conviction.The petitioner filed a habeas petition in 2016, claiming that the admission of unduly suggestive and unreliable eyewitness identification evidence violated his due process rights. He also argued that advances in the science of eyewitness identification since his conviction called into question the validity of his conviction. The habeas court dismissed these claims, concluding they were barred by res judicata and that the decisions in State v. Guilbert and State v. Dickson did not apply retroactively. The court also dismissed and denied other claims of ineffective assistance of counsel.The Connecticut Supreme Court reviewed the case and concluded that the principles set forth in Dickson, which addressed the suggestiveness of first-time, in-court identifications, must apply retroactively on collateral review. The court reasoned that the rule in Dickson was a result of scientific developments that significantly improve the accuracy of convictions and that the petitioner had raised similar claims in his direct appeal. The court reversed the Appellate Court's decision and remanded the case for a trial on the petitioner's due process and actual innocence claims, directing the lower court to apply the holding of Dickson retroactively. View "Tatum v. Commissioner of Correction" on Justia Law

The case involves a dispute over the taxability of personal property used by a hospital at an outpatient rehabilitation facility. The plaintiff, a hospital owned by a health system, operates a rehabilitation facility in a leased suite. The plaintiff claimed that the personal property used at this facility was exempt from taxation under Connecticut General Statutes § 12-81 (7) or (16), which provide tax exemptions for charitable and hospital property, respectively. The town's assessor denied the tax exemption, and the town's board of assessment appeals upheld this denial.The trial court reviewed the case and sided with the plaintiff, granting its motion for summary judgment. The court reasoned that although the plaintiff is part of a health system, the personal property was located at a leased facility, not owned by the health system, and therefore did not fall under the purview of General Statutes § 12-66a. The court concluded that the personal property was exempt from taxation under § 12-81 (7) and (16).The Connecticut Supreme Court reviewed the case and reversed the trial court's decision. The Supreme Court held that the personal property used at the rehabilitation facility is taxable under § 12-66a, even if it would otherwise be exempt under § 12-81 (7) or (16). The Court determined that the term "acquired" in § 12-66a includes leased property, not just purchased property. The Court emphasized that the statute aims to protect municipalities from losing tax revenue due to health systems acquiring tax-exempt status for properties they use, whether owned or leased. The Court also clarified that the plaintiff, as part of a health system, falls under the statute's provisions, making the personal property taxable.The Supreme Court reversed the trial court's judgment and remanded the case with directions to deny the plaintiff's motion for summary judgment and for further proceedings. View "William W. Backus Hospital v. Stonington" on Justia Law

The plaintiff, a religious organization, sought to reclaim possession of a commercial property occupied by the defendants through a summary process action. The dispute arose after the founder and former president of the plaintiff, D, transferred his responsibilities to S in 2014. S took possession of the property and operated two companies from it, making regular mortgage payments until his relationship with D deteriorated, leading to a cessation of payments. D then ordered S to vacate the property and purported to remove him from his position. The parties agreed to resolve their disputes before a Bais Din, a rabbinical tribunal, which ruled that S would continue as the leader and make mortgage payments, while D retained ownership of the property for three years.The trial court, the Superior Court in the judicial district of Stamford-Norwalk, initially denied the defendants' motion to dismiss the action for lack of subject matter jurisdiction but ordered a stay to allow arbitration before the Bais Din. The court found that D had signed the arbitration agreement intending to bind the plaintiff and that the ownership issue was to be adjudicated by the Bais Din. However, after the stay period, the court denied the defendants' motion to stay the proceedings and compel arbitration, concluding that the plaintiff was not a party to any arbitration agreement and that the court would resolve the ownership and landlord-tenant issues.The Supreme Court of Connecticut reviewed the case and found that the trial court erred in failing to enforce the arbitration agreement. The court held that the plaintiff was bound by the arbitration agreement, as D signed it in a representative capacity with the intent to bind the plaintiff. The court noted that the arbitration agreement covered all disputes between the parties, including the issue of possession of the property. Consequently, the Supreme Court reversed the trial court's judgment and remanded the case with direction to grant the defendants' motion to stay the proceedings and compel arbitration. View "Chabad Lubavitch of Western & Southern New England, Inc. v. Shemtov" on Justia Law

In a civil action for underinsured motorist benefits, a law firm representing the plaintiff engaged in ex parte communications with an orthopedic surgeon disclosed by the defendant insurance company as an expert witness. The firm scheduled an appointment for the expert to examine the plaintiff and subsequently disclosed the expert as their own witness, indicating that the expert would testify that the plaintiff's shoulder injury was related to the accident. The expert's report, following the examination, supported this causation.The trial court disqualified the expert from testifying and imposed sanctions on the law firm, requiring it to pay the defendant for the expenses incurred in retaining the expert. The court concluded that the law firm's conduct violated Practice Book § 13-4, which it interpreted as implicitly prohibiting ex parte communications with an opposing party's disclosed expert witness. The Appellate Court reversed the trial court's order, finding that Practice Book § 13-4 did not clearly prohibit such ex parte communications.The Connecticut Supreme Court affirmed the Appellate Court's decision, agreeing that Practice Book § 13-4 was not reasonably clear in prohibiting ex parte communications with an opposing party's disclosed expert witness. The court emphasized that the rule's current version lacks explicit limiting language and that the difference in treatment between disclosed expert witnesses and nontestifying experts in the rule supports this conclusion. The court declined to exercise its supervisory authority to create a new rule prohibiting such conduct, noting that the issue did not rise to a level warranting such an extraordinary remedy. View "Epright v. Liberty Mutual Ins. Co." on Justia Law

The plaintiff, a property owner in Fairfield, Connecticut, sought approval from the town's zoning commission to build a forty-unit affordable housing development. The application included a request for a text amendment to the zoning regulations and approval of a site plan and certificate of zoning compliance. The proposed building exceeded the height limits of the residence A zone district, where the property is located, which typically allows only single-family dwellings with a maximum height of thirty-two feet.The zoning commission denied the text amendment request, citing inconsistency with the town's plan of conservation and development, among other reasons. However, it conditionally approved the site plan and certificate of zoning compliance, provided the building height was reduced to three stories and forty feet. The commission justified the height restriction by stating that the proposed building's visibility from a nearby historic district would harm the district's integrity, which it deemed a substantial public interest.The plaintiff appealed to the Superior Court, which consolidated the case with an appeal from four intervenors who opposed the development. The trial court ruled in favor of the plaintiff, finding that the commission had improperly failed to apply the standards of Connecticut's affordable housing statute (§ 8-30g) to the text amendment request. The court also concluded that the commission did not meet its burden of proving that the height restriction was necessary to protect a substantial public interest that outweighed the need for affordable housing.The Connecticut Supreme Court affirmed the trial court's decision regarding the height restriction, agreeing that the commission failed to demonstrate that the restriction was necessary to protect a substantial public interest in historic preservation that outweighed the need for affordable housing. However, the Supreme Court partially reversed the trial court's decision on the text amendment, ruling that § 8-30g applied only to the plaintiff's property and not to the entire residence A zone district. The case was remanded with instructions to grant the text amendment limited to the plaintiff's property. View "131 Beach Road, LLC v. Town Plan & Zoning Commission" on Justia Law

A nonprofit association of homeowners in Woodbridge appealed a decision by the Connecticut Siting Council, which approved a telecommunications company's application to construct a cell phone tower in the town. The plaintiff intervened in the administrative proceeding, arguing that the proposed tower would unreasonably impact nearby scenic resources and vistas. During the hearings, the council stated that property values were not among the statutory criteria to be considered. The telecommunications company presented evidence that the tower would improve cell coverage, while the plaintiff's consultant argued that alternative locations would provide better coverage with less impact on residential neighborhoods.The trial court dismissed the plaintiff's administrative appeal, concluding that the council's decision was supported by substantial evidence and was reasonable. The court noted that the council had considered evidence from residents about the tower's impact on property values and had sufficiently considered alternative locations but found the approved site to be the most appropriate.The Connecticut Supreme Court reviewed the case and held that the plaintiff had standing to raise the claim about property values. However, the court concluded that a facility's impact on property values is not an enumerated or unenumerated significant adverse effect that the council must consider under the statute. The court also found that the council's decision was supported by substantial evidence, including extensive testimony and documentary evidence about the coverage provided by the proposed and alternative locations. The court affirmed the trial court's judgment, upholding the council's approval of the tower. View "Woodbridge Newton Neighborhood Environmental Trust v. Connecticut Siting Council" on Justia Law

The plaintiff, a manufacturer of resinous flooring systems, sued a former employee, the defendant, for breaching a noncompete agreement, violating the Connecticut Uniform Trade Secrets Act (CUTSA), and breaching a common-law duty of confidentiality. The defendant, who had signed a noncompete agreement as a condition of continued employment, later established his own floor coating business and used the plaintiff’s proprietary information to develop competing products. The plaintiff alleged that the defendant also assisted competitors in developing their products.In a separate but related case, the trial court found the noncompete agreement unenforceable due to lack of consideration and ruled that the common-law duty of confidentiality claim was preempted by CUTSA. The court also determined that a payment made to the defendant after his resignation was severance pay, not compensation for reaffirming the noncompete agreement. Based on these findings, the trial court in the present case granted summary judgment for the defendant, applying collateral estoppel to preclude further consideration of the issues.The Connecticut Supreme Court reviewed the case and concluded that the trial court had incorrectly determined the noncompete agreement was unenforceable for lack of consideration. The Supreme Court reversed the trial court’s judgment on the breach of the noncompete agreement claim and remanded the case for further proceedings to determine whether the agreement was supported by adequate consideration. The court upheld the trial court’s findings that the severance payment was not consideration for reaffirming the noncompete agreement and that the common-law duty of confidentiality claim was preempted by CUTSA. These rulings were binding in the present case. The judgment was reversed in part and affirmed in part, with further proceedings required to determine the enforceability and potential breach of the noncompete agreement. View "Dur-A-Flex, Inc. v. Dy" on Justia Law