Justia Connecticut Supreme Court Opinion Summaries

by
The case revolves around a dispute over workers' compensation benefits. The plaintiff, an employee of Frank Lill & Son, Inc., claimed to have sustained two separate injuries during his employment. He sent a written notice of claim to his employer and the Workers’ Compensation Commission. The employer, within twenty-eight days of receiving the plaintiff’s notice of claims, mailed a notice of intention to contest the plaintiff’s right to compensation benefits. However, the administrative law judge did not receive the notice of intention until after the twenty-eight day statutory period had elapsed. The plaintiff then filed a motion to preclude the defendants from contesting liability, arguing that the employer had failed to commence payment of the claims or to file a notice of intention to contest the claims within the required timeframe.The administrative law judge granted the plaintiff’s motion, concluding that the employer had failed to meet the requirements of the statute, and therefore, the defendants were presumed to have accepted the compensability of the plaintiff’s alleged injuries and were precluded from contesting his claims. The Compensation Review Board upheld the administrative law judge’s decision.The case was then brought before the Connecticut Supreme Court. The defendants argued that they had met their statutory obligation by mailing the notice within the statutory period, and that "mailing" should be considered the same as "filing" for the purposes of the statute. However, the court disagreed, stating that the statutory language was clear that the notice of intention to contest must be delivered, not just mailed, to the administrative law judge within the specified timeframe. The court also noted that the use of different terms in the same statute suggested that the legislature intended for the terms to have different meanings. The court affirmed the decision of the Compensation Review Board, ruling that the employer had not met its statutory obligation. View "Ajdini v. Frank Lill & Son, Inc." on Justia Law

by
The case revolves around a dispute over visitation rights for a minor child, L. The plaintiff, Laurie Hepburn, is the sister of L's deceased mother and had lived with L since her birth in 2010. After the death of L's mother in 2021, L's father, the defendant Chandler Brill, took L to live with him full-time. Hepburn filed a petition for visitation rights, which Brill moved to dismiss for lack of subject matter jurisdiction, arguing that Hepburn lacked standing under the third-party visitation statute because she failed to allege sufficient facts to establish that she had a parent-like relationship with L and that L would suffer real and significant harm if visitation were denied.The trial court granted the defendant's motion to dismiss the initial petition, concluding that it did not satisfy the requirements of the third-party visitation statute. The court also dismissed, on its own, the amended petition, concluding that its allegations, if proven by clear and convincing evidence, would not establish the plaintiff’s parent-like relationship with L or establish that L would suffer real and significant harm if visitation were to be denied.The Supreme Court of Connecticut reversed the trial court's judgment, holding that the trial court improperly dismissed the plaintiff’s amended petition for visitation with L. The court found that the plaintiff had adequately alleged both the existence of a parent-like relationship and that the denial of visitation would cause L real and significant harm. The case was remanded for further proceedings. View "Hepburn v. Brill" on Justia Law

Posted in: Family Law
by
The case involves a dispute between Mercedes-Benz Financial and 1188 Stratford Avenue, LLC, and its principal, Aniello Dizenzo. The plaintiff, Mercedes-Benz Financial, alleged that the defendants breached a motor vehicle lease agreement by failing to make payments. After the defendants failed to appear, the trial court granted the plaintiff's motion for judgment and rendered a default judgment in favor of the plaintiff. The defendants later moved to open and set aside the default judgment, arguing that the vehicle had serious defects, making it dangerous to operate, and that they had returned the vehicle to the dealership. They also claimed that they mistakenly thought the case had been resolved.The trial court denied the defendants' motion to open the judgment, concluding that the motion was untimely and had no basis. The defendants appealed to the Appellate Court, which acknowledged that the trial court incorrectly determined that the motion was untimely but upheld the trial court's decision, concluding that it had not abused its discretion in denying the motion on the ground that it had no basis.The defendants then appealed to the Connecticut Supreme Court. The Supreme Court held that the Appellate Court incorrectly concluded that the trial court had not abused its discretion in denying the defendants’ motion to open. The Supreme Court found that the trial court's determination that the motion was untimely was incorrect, and this error likely affected the trial court's decision on the merits of the motion. The Supreme Court reversed the Appellate Court’s judgment and remanded the case for further proceedings, directing the lower court to reverse its judgment and conduct an evidentiary hearing on the defendants' motion to open the judgment. View "Mercedes-Benz Financial v. 1188 Stratford Avenue, LLC" on Justia Law

by
The case revolves around a plaintiff who was arrested for operating a motor vehicle while under the influence of intoxicating liquor. The arresting officer prepared a report of the incident and mailed it to the Department of Motor Vehicles (DMV), but not within the three business days required by statute. At the plaintiff's license suspension hearing, the plaintiff's attorney objected to the admission of the report on the grounds that it was not prepared and mailed within the statutory timeframe. The hearing officer overruled the objection and admitted the report, which was the only evidence submitted at the hearing.The trial court dismissed the plaintiff's appeal, concluding that strict adherence to the preparation and mailing requirement was not necessary for the report to be admissible. The Appellate Court affirmed the trial court's judgment, concluding that the preparation and mailing requirement is directory, and therefore, strict compliance with that requirement is not necessary for a report to be admissible at a license suspension hearing.The Supreme Court of Connecticut reversed the Appellate Court's judgment. The court held that the hearing officer abused her discretion in admitting an incident report that did not strictly comply with the preparation and mailing provision of the statute in the absence of testimony from the arresting officer. The court concluded that the preparation and mailing requirement was mandatory because it promoted the accuracy and reliability of the information that would be used at a license suspension hearing. The court clarified that the statute describes substantive requirements that incident reports must meet, and the failure to meet those requirements renders a report inadmissible insofar as it fails to satisfy the exception for the report to be admitted without the need to produce the arresting officer at the suspension hearing. View "Marshall v. Commissioner of Motor Vehicles" on Justia Law

by
The defendant, Gonzalo Diaz, was convicted of felony murder, burglary in the first degree, conspiracy to commit burglary in the first degree, attempt to commit robbery in the first degree, and criminal possession of a firearm in connection with a shooting death. The defendant appealed, claiming that the trial court committed plain error by instructing the jury that it could consider his interest in the outcome of the trial when assessing his credibility. He also claimed that the prosecutor made improper remarks during his cross-examination and during rebuttal argument.The Superior Court in the judicial district of Waterbury found Diaz guilty of felony murder, manslaughter in the first degree with a firearm, burglary in the first degree, conspiracy to commit burglary in the first degree, and attempt to commit robbery in the first degree. The court also found him guilty of criminal possession of a firearm. The court later vacated the conviction for manslaughter in the first degree with a firearm.The Connecticut Supreme Court affirmed the lower court's decision. The court agreed that the trial court's instruction to the jury was erroneous, but it did not result in manifest injustice. The court also found that the prosecutor's remarks were not improper. The court concluded that the defendant failed to establish that the evidence adduced at trial, the disputed factual issues before the jury, and the instructions as a whole gave rise to the danger of juror misunderstanding or confusion. Therefore, the court affirmed the judgment of the trial court. View "State v. Diaz" on Justia Law

Posted in: Criminal Law
by
The case involves two plaintiffs, Glen A. Canner and Louis D. Puteri, who separately sued a condominium association, Governors Ridge Association, Inc., alleging that the foundations supporting their respective units were defective. The units, part of a common interest community, were purchased by Canner and Puteri in 2001 and 2002 respectively. The defendant had affirmed its responsibility for any foundation settlement issues. However, despite the units suffering significant, uneven settling and the defendant hiring several companies to investigate potential repairs from 2012 to 2016, no repairs were ultimately made. The plaintiffs commenced their actions in 2016 and 2017, alleging that the defendant had negligently designed and constructed the foundations and had violated its duties under the Common Interest Ownership Act (CIOA) by failing to conduct necessary repairs.The trial court concluded that the CIOA claims were time-barred by the statutory three-year limitation period generally applicable to tort actions. The Appellate Court affirmed the trial court’s judgments, concluding that the limitation period set forth in § 52-577 applied because the claims sounded in tort rather than contract. The Appellate Court also agreed with the trial court’s conclusion that the declaration and bylaws created no duty to repair because the relevant declaration required the defendant to repair only insured common elements, and there was no requirement that the foundations themselves be insured.The Supreme Court of Connecticut held that the Appellate Court properly applied the statute of limitations set forth in § 52-577 to the portion of the CIOA claims seeking recovery for negligence during the course of construction of the foundations. However, the Supreme Court found that the Appellate Court improperly upheld the trial court’s disposition, in favor of the defendant, of the claims that the defendant had violated its contractual duties under the bylaws to maintain, repair or replace common elements when it failed to effectuate repairs to the foundations. The Supreme Court concluded that the claims that the defendant breached its contractual duties imposed under the bylaws by failing to repair the foundations were governed by the six-year limitation period applicable to contract claims in § 52-576. The case was affirmed in part, reversed in part, and remanded for further proceedings. View "Canner v. Governors Ridge Assn., Inc." on Justia Law

by
The defendant, Dwayne Sayles, was convicted of felony murder and conspiracy to commit robbery in the first degree, among other crimes, in connection with his role in the robbery of a convenience store and the shooting death of the store clerk. On appeal, Sayles challenged the trial court's denial of his motions to suppress evidence of his cell phone and the data contained therein. He argued that the police had violated his rights under Miranda and the Connecticut constitution when they continued to interrogate him after he had invoked his right to counsel, and that the seizure of his cell phone violated the fourth amendment to the U.S. constitution and the Connecticut constitution.However, the Supreme Court of Connecticut concluded that any error in the admission of the contents of Sayles' cell phone was harmless beyond a reasonable doubt due to the overwhelming wealth of evidence against him. This evidence included surveillance footage from inside of the convenience store, detailed testimony from a co-conspirator about Sayles' and his own involvement in the events, testimony from a jailhouse informant that Sayles had confessed to his involvement in the crimes, and a corroborating statement made to the police by a friend of Sayles. The court also noted significant evidence of Sayles' consciousness of guilt, such as testimony that he had directed his cousin to assault a potential witness to force him to recant his testimony. Physical evidence, including a ski mask and gloves found during the search of Sayles' residence and cell phone location data, further corroborated the testimony and statements. Given this, the court affirmed the Appellate Court’s judgment and declined to address Sayles' constitutional challenges. View "State v. Sayles" on Justia Law

by
In this case, the defendant, Lawrence Lee Henderson, was convicted of home invasion after a jury trial. During the trial, the defendant contracted COVID-19, resulting in a 25-day delay in jury deliberations. When the deliberations resumed, the jury found the defendant guilty of home invasion but not guilty of other charges and lesser included offenses.The defendant appealed, claiming that the court should reverse his conviction of home invasion or grant him a new trial on that charge because the jury’s verdicts of guilty of home invasion and not guilty of a lesser included offense were legally inconsistent. He also claimed that the trial court abused its discretion by failing to declare a mistrial when he contracted COVID-19, which resulted in the delay in jury deliberations.The court upheld the trial court’s decision, holding that legally inconsistent verdicts are unreviewable on appeal, following its precedent in State v. Arroyo, which was consistent with United States Supreme Court precedent and that of the majority of other jurisdictions. In terms of the COVID-19 delay, the court found that the trial court did not abuse its discretion in denying the defendant's motion for a mistrial, as the delay was unavoidable due to the pandemic, and the defendant failed to demonstrate actual prejudice from the delay. View "State v. Henderson" on Justia Law

Posted in: Criminal Law
by
The plaintiff, the only child of the decedent, filed a lawsuit against the defendant, the decedent's second husband, for tortious interference with the plaintiff’s expected inheritance. The decedent had left her estate to the defendant and disinherited the plaintiff in her will. After her death, the defendant applied to have the will admitted to probate, which the plaintiff contested on several grounds, including undue influence. The Probate Court rejected the plaintiff's claims and admitted the will to probate. The plaintiff appealed to the Superior Court, where the appeal was set for a de novo trial. The defendant moved for summary judgment in the tort action, asserting that the plaintiff’s claims were barred by the doctrines of res judicata and collateral estoppel. The trial court denied the motion for summary judgment.The defendant appealed the partial denial of his motion for summary judgment to the Appellate Court. The court dismissed the appeal for lack of subject matter jurisdiction, concluding that there was no appealable final judgment. Upon certification, the Supreme Court reversed the decision of the Appellate Court.The Supreme Court held that the Appellate Court improperly dismissed the defendant’s appeal from the trial court’s partial denial of his motion for summary judgment. The court reasoned that the trial court correctly rejected the defendant’s collateral estoppel claim, although on different grounds. The Supreme Court explained that the Probate Court's decision regarding the plaintiff’s undue influence claim had no force in the probate appeal because the trial court, conducting a trial de novo, would decide on the undue influence claim without regard to the Probate Court’s findings or rulings. Therefore, the Probate Court decree did not have the necessary attributes of finality to warrant the application of the doctrine of collateral estoppel. The Supreme Court remanded the case to the Appellate Court with direction to affirm the trial court’s denial of the defendant’s motion for summary judgment and to direct the trial court to conduct further proceedings. View "O'Sullivan v. Haught" on Justia Law

Posted in: Trusts & Estates
by
This case involves a lieutenant with the Hartford Police Department who filed a bill of discovery against a blogger who writes about Hartford municipal governance. The plaintiff is seeking to compel the defendant to release data that would reveal the identities of anonymous commenters on the blog who posted allegedly defamatory statements about him. The plaintiff also wants the defendant's laptop and cellphone to be submitted for forensic analysis.The trial court granted the plaintiff's bill of discovery, stating that the plaintiff had shown probable cause for his defamation claim against the authors of certain anonymous comments. The court ordered that the parties should try to agree on a protective order and search protocols to safeguard the defendant's privacy during the forensic analysis. If they couldn't agree, the court would resolve the dispute. The defendant appealed the decision before any negotiations took place.The Supreme Court of Connecticut dismissed the defendant's appeal, stating that the trial court's decision was not an appealable final judgment. The Court explained that the final judgment rule applies to a pure bill of discovery, and the trial court's decision wouldn't become a final judgment until the scope of discovery was clearly defined either by the parties' agreement or by court order. In this case, the parties hadn't yet complied with the court's order to either agree on the terms of the protective order and search protocols or to return to the court for resolution of those issues. Therefore, the trial court's decision was not a final judgment. View "Benvenuto v. Brookman" on Justia Law