Justia Connecticut Supreme Court Opinion Summaries

The defendant was previously convicted of murder and criminal possession of a firearm. This court reversed the murder conviction due to the prosecutor's improper comments on the defendant's post-Miranda silence, violating Doyle v. Ohio. The defendant then moved to dismiss the murder charge, arguing that double jeopardy protections barred a retrial because the prosecutor intended to prevent an acquittal that was imminent without the impropriety.The trial court denied the motion to dismiss, finding that the defendant did not establish that the prosecutor intended to prevent an acquittal. The court based its decision on the trial transcripts and this court's previous decision, which concluded that the evidence was sufficient to support the conviction. The defendant appealed, renewing his argument that the double jeopardy clause barred a retrial and asserting that the Connecticut constitution provided broader protections.The Supreme Court of Connecticut affirmed the trial court's decision. The court held that the defendant failed to demonstrate that the prosecutor engaged in impropriety with the intent to prevent an acquittal that the prosecutor believed was imminent. The court noted that the evidence at trial, although not overwhelming, was sufficient to support a conviction, and the prosecutor's actions did not indicate an intent to provoke a mistrial or prevent an acquittal. The court also declined to overrule its previous decisions in State v. Colton and State v. Michael J., maintaining that the Connecticut constitution does not provide broader double jeopardy protections than the federal constitution. View "State v. Patrick M." on Justia Law

The case involves a dispute between two cotrustees of the William A. Rutherford Trust regarding the distribution of the trust estate following the deaths of the grantors, William and Joyce Rutherford. The plaintiff, Jeffrey A. Rutherford, and the defendant, Richard J. Slagle, could not agree on how the trust estate should be distributed. The defendant believed the trust required equal distribution among the decedent’s children, while the plaintiff disagreed.The defendant petitioned the Greenwich Probate Court to construe the trust and determine the proper distribution. The Probate Court granted the petition and ordered the trust estate to be distributed equally among the children. The plaintiff appealed this decree to the Superior Court, challenging the Probate Court’s decision and raising issues related to discovery in the Probate Court.The Superior Court granted the defendant’s motion for summary judgment, reasoning that the plaintiff’s reasons for appeal were limited to discovery issues and that there was no genuine issue of material fact regarding these issues. The plaintiff then appealed to the Connecticut Supreme Court, arguing that summary judgment is not appropriate in probate appeals and that the Superior Court failed to conduct a de novo review of the Probate Court’s decision.The Connecticut Supreme Court held that summary judgment is available in probate appeals under Practice Book § 17-44, as the term “any action” includes probate appeals. However, the court found that the Superior Court improperly granted summary judgment because it did not engage in a de novo review of the substantive issue resolved by the Probate Court—how the trust estate should be distributed. The Supreme Court reversed the judgment and remanded the case for further proceedings consistent with its opinion. View "Rutherford v. Slagle" on Justia Law

The plaintiff, a residential substance abuse treatment program operator, sought a special permit from the defendant, the Planning and Zoning Commission of the Town of Kent, to construct a greenhouse on its farm parcel. The plaintiff had been using the farm parcel for agricultural therapy as part of its treatment program, a use that became nonconforming after the town amended its zoning regulations in 2020 to prohibit privately operated clinics in rural residential districts. The commission denied the application, citing concerns that the greenhouse would impermissibly expand the nonconforming use by extending it from a seasonal to a year-round operation.The trial court upheld the commission's decision, dismissing the plaintiff's administrative appeal. The court found that the proposed greenhouse would indeed expand the nonconforming use, which was limited to the terms of the 2018 special permit and site plan approval. The court also noted that the commission's decision was consistent with the zoning regulations' intent to limit nonconforming uses.The Appellate Court reversed the trial court's judgment, concluding that the greenhouse was a permissible intensification of the nonconforming use. The court reasoned that the greenhouse would be located on land already used for agricultural therapy and would not change the nature, character, or kind of use involved. The court also found insufficient evidence to support the commission's concerns about adverse effects on the neighborhood.The Supreme Court of Connecticut reversed the Appellate Court's judgment, holding that the installation of the greenhouse would impermissibly expand the plaintiff's nonconforming use from seasonal to year-round. The court emphasized that extending a seasonal use into a year-round operation changes the character of the use, which is not permissible under zoning regulations. The case was remanded to the Appellate Court with direction to affirm the trial court's dismissal of the plaintiff's administrative appeal. View "High Watch Recovery Center, Inc. v. Planning & Zoning Commission" on Justia Law

The defendant was convicted of unlawful restraint in the second degree, sexual assault in the fourth degree, attempt to commit sexual assault in the third degree, and sexual assault in the third degree. The charges stemmed from an incident where the defendant allegedly assaulted the victim, C, in his home. C testified that the defendant made unwanted advances, restrained her, and sexually assaulted her. The defendant argued that C fabricated the story due to a rent dispute between the defendant and C's mother, K.The trial court found the defendant guilty on all charges, and the Appellate Court affirmed the conviction. The defendant appealed, claiming that the prosecutor's remarks during rebuttal closing argument were improper and deprived him of a fair trial. Specifically, the prosecutor listed common defenses in criminal cases and referred to the "nuts and sluts" defenses in sexual assault cases, suggesting that C would have to be "nuts" to fabricate her story.The Supreme Court of Connecticut reviewed the case and determined that the prosecutor's use of the phrase "nuts and sluts" was improper as it appealed to the jurors' emotions and diverted their attention from the evidence. The court also found that the prosecutor's listing of defenses was improper because it was unrelated to the evidence presented at trial. However, the court concluded that these improprieties did not deprive the defendant of a fair trial.The court applied the factors from State v. Williams to assess the impact of the improprieties. It found that the prosecutor's statements were not severe, were infrequent, and the state's case was relatively strong. The court also noted that defense counsel did not object to the statements or request curative instructions. As a result, the Supreme Court of Connecticut affirmed the judgment of the Appellate Court. View "State v. Sullivan" on Justia Law

In 2017, the Commissioner of Children and Families obtained an order of temporary custody for a minor child, Andrew, and placed him with foster parents. Years later, the foster parents filed a motion to intervene in response to the biological father's motion to revoke Andrew's commitment, which was granted in 2020. In 2021, the court denied the father's motion to revoke commitment, granted the foster parents' motion to transfer guardianship of Andrew to them, and rendered judgment accordingly.In 2023, the Appellate Court decided In re Ryan C., holding that nonrelative foster parents are prohibited by statute from intervening in neglect proceedings. Following this decision, the biological father filed a motion to open and vacate the 2021 judgment transferring guardianship of Andrew to the foster parents, arguing that the court lacked subject matter jurisdiction to entertain the foster parents' motion to transfer guardianship. The trial court agreed, vacating the order granting the foster parents' motion to intervene and the judgment transferring guardianship.The Supreme Court of Connecticut reviewed the case and reversed the Appellate Court's judgment. The Supreme Court held that the Appellate Court improperly upheld the trial court’s decision to grant the father's motion to open and vacate the 2021 judgment. The Supreme Court determined that the trial court had jurisdiction to grant the foster parents' motion to intervene and their motion to transfer guardianship in 2021. Consequently, the trial court lacked authority to open the 2021 judgment more than four months after notice of that judgment was sent. The Supreme Court directed the Appellate Court to reverse the trial court’s decision and to reinstate the earlier order granting the foster parents’ motion to intervene and the 2021 judgment transferring guardianship of Andrew to the foster parents. View "In re Andrew C." on Justia Law

The defendant was convicted of risk of injury to a child in 2012 and sentenced to fifteen years of incarceration, execution suspended after five years, followed by twenty-five years of probation. As a condition of his probation, the court prohibited him from contacting the victim. In 2021, the state sought a standing criminal protective order against the defendant, which the trial court granted, requiring the defendant to have no contact with the victim and to remain at least 100 yards away from her, among other conditions. The order was set to remain in effect for forty years.The defendant appealed to the Appellate Court, arguing that the trial court abused its discretion by issuing the protective order without evidence of a change in circumstances since his sentencing. The Appellate Court majority upheld the trial court’s decision, concluding that the defendant did not challenge the imposition of the order on the ground that the court failed to abide by the statutory standard. The dissenting judge disagreed, interpreting the defendant’s argument as asserting that the statute required evidence of a change in circumstances.The Supreme Court of Connecticut reviewed the case and concluded that the defendant adequately briefed his claim that additional requirements apply when a standing criminal protective order is issued postsentencing. The court held that, in addition to the express requirements of § 53a-40e (a), the issuing court must find that additional evidence, not presented at sentencing, indicates that the order will best serve the interests of the victim and the public. The trial court failed to apply this standard, as it did not find that the defendant had been convicted of a qualifying offense or that additional evidence supported the issuance of the order. Consequently, the Supreme Court reversed the Appellate Court’s judgment and remanded the case with direction to vacate the trial court’s order. View "State v. Mieles" on Justia Law

The defendant was on probation after being convicted of conspiracy to commit murder. His probation was revoked based on allegations that he participated in a home invasion, left the state without permission, and failed to submit to substance abuse evaluations and counseling. The defendant contested the revocation, particularly challenging the admission of an out-of-court identification by a witness, Rainey, who was unavailable for cross-examination.The trial court admitted Rainey’s identification without applying the balancing test required by State v. Crespo, which weighs the defendant’s right to confront witnesses against the state’s reasons for not producing the witness and the reliability of the evidence. The court found the defendant violated his probation and imposed a thirteen-year sentence. The defendant appealed, arguing the trial court erred by not applying the Crespo balancing test.The Appellate Court affirmed the trial court’s decision, concluding that the defendant had abandoned his request for the Crespo balancing test during the probation revocation hearing. The defendant then appealed to the Connecticut Supreme Court.The Connecticut Supreme Court found that the defendant did not abandon his Crespo claim. The court noted that the defendant consistently argued for the application of the Crespo balancing test and that the trial court should have engaged in this balancing before admitting Rainey’s identification. The Supreme Court reversed the Appellate Court’s judgment in part and remanded the case for a new probation revocation hearing limited to determining whether the defendant was involved in the home invasion. The findings that the defendant violated other conditions of his probation were upheld and not to be relitigated. View "State v. Wade" on Justia Law

The plaintiff sought to foreclose two municipal tax liens for the grand lists of 2012 and 2013 on real property owned by the defendant. The city of Bridgeport had purportedly assigned the tax liens to the plaintiff’s predecessor, which then allegedly assigned its interest to the plaintiff. The defendant filed an answer and several special defenses, including a claim that the Bridgeport City Council had not validly assigned the liens. The trial court granted the plaintiff’s motion for summary judgment as to liability, concluding there was no genuine issue of material fact regarding the validity of the assignments. Subsequently, the trial court rendered a judgment of foreclosure by sale.The defendant appealed to the Appellate Court, which affirmed the trial court’s judgment. The defendant then appealed to the Connecticut Supreme Court, arguing that the plaintiff did not provide sufficient proof that the city council had made a resolution to assign the tax liens to the plaintiff.The Connecticut Supreme Court affirmed the Appellate Court’s decision, holding that the plaintiff had met its burden of establishing the validity of the assignments. The court found that the plaintiff submitted certified copies of the city council’s meeting agendas and minutes, which showed that the council had authorized the assignments. The court also noted that the defendant failed to present any evidence to create a genuine issue of material fact regarding the validity of the assignments. The court clarified that the plaintiff bore the burden of proving standing and had satisfied this burden, while the defendant’s mere assertions were insufficient to defeat summary judgment. The court also addressed procedural irregularities but concluded that the defendant had waived any related claims by not objecting. View "Cazenovia Creek Funding I, LLC v. White Eagle Society of Brotherly Help, Inc." on Justia Law

A national consumer advocate law firm (C Co.) and its affiliate (S Co.) providing administrative support services sought injunctive and declaratory relief against the Department of Banking. The Department had initiated an administrative enforcement action against S Co. for allegedly engaging in unlicensed debt negotiation activities. The plaintiffs argued that S Co. was exempt from licensing requirements under a presumption established in a prior case (Persels & Associates, LLC v. Banking Commissioner), which holds that attorneys providing debt negotiation services as part of their legal practice fall under the exclusive regulation of the Judicial Branch.The trial court denied the Department's motion to dismiss the plaintiffs' action, concluding that the plaintiffs were not required to exhaust administrative remedies before seeking judicial intervention on whether the Persels presumption applied to S Co. The Department appealed, arguing that the Commissioner of Banking should first determine whether the presumption applied.The Supreme Court of Connecticut affirmed the trial court's decision, holding that the plaintiffs were not required to exhaust administrative remedies before seeking judicial intervention. The court reasoned that the Commissioner of Banking lacks the expertise to determine whether the Persels presumption applies, as this involves assessing whether the activities in question constitute the practice of law, which falls under the exclusive authority of the Judicial Branch. The court emphasized that allowing the commissioner to make this determination would violate the constitutional separation of powers. Therefore, the plaintiffs could seek declaratory and injunctive relief in the trial court without waiting for the commissioner to resolve the issue. View "Commonwealth Servicing Group, LLC v. Dept. of Banking" on Justia Law

The defendant was convicted of murder and criminal violation of a standing criminal protective order. During the trial, the defendant elected to represent himself. However, the trial court reappointed his former standby counsel to represent him due to the defendant's conduct, including his conscious decision not to appear in court on a particular occasion.The trial court found that the defendant's conduct, which included refusing court-ordered transportation, failing to appear at scheduled hearings, and threatening to leave trial proceedings, constituted a forfeiture of his right to self-representation. The trial court noted that the defendant's behavior was dilatory, disruptive, and manipulative. The trial court reappointed standby counsel to regain control of the courtroom and the trial schedule.The Connecticut Supreme Court reviewed the case and affirmed the trial court's decision. The Supreme Court held that the trial court did not violate the defendant's right to self-representation. The court found that the defendant's conduct, including his refusal to return to court after a lunch break, was sufficiently disruptive and obstructionist to warrant a forfeiture of his right to self-representation. The court emphasized that the trial court had warned the defendant about the consequences of his actions and had given him multiple opportunities to conform to the rules before making the forfeiture finding. The Supreme Court concluded that the trial court properly exercised its discretion to reappoint counsel to ensure a fair trial. View "State v. Petteway" on Justia Law