Justia Connecticut Supreme Court Opinion Summaries

The defendant was involved in a fatal shooting after following the victim’s vehicle, approaching the victim, and engaging in a verbal confrontation that escalated. The defendant attempted to grab a BB gun from the victim, failed, and then fired four shots with his own firearm, striking and ultimately killing the victim. The defendant claimed he acted in self-defense, asserting he believed the victim was about to use deadly force against him. The evidence included eyewitness testimony and physical evidence regarding the sequence of events and the location of weapons at the scene.The case was initially tried in the Superior Court in the judicial district of New Haven. The jury found the defendant not guilty of murder but guilty of intentional manslaughter in the first degree with a firearm, carrying a pistol or revolver without a permit, and criminal possession of a firearm. The defendant was sentenced to thirty-three years of imprisonment. On appeal, he challenged only his conviction for intentional manslaughter, arguing that (1) the trial court had failed to instruct the jury to unanimously agree on which statutory disqualification to self-defense applied, (2) the jury instructions were misleading regarding the initial aggressor and recklessness-based offenses, and (3) the evidence was insufficient to disprove self-defense or establish intent.The Supreme Court of Connecticut reviewed the appeal. It held that, consistent with its reasoning in State v. Mekoshvili, the federal constitution does not require jurors to unanimously agree on which specific statutory disqualification to self-defense was established, so long as they unanimously reject self-defense. The Court also found no merit in the defendant’s claims of instructional error or insufficiency of evidence. The judgment of the Superior Court was affirmed. View "State v. Matheney" on Justia Law

The case concerns an individual convicted of felony murder, first-degree robbery, and conspiracy to commit first-degree robbery related to a shooting death during a transaction arranged via Craigslist. Key facts established that the victim met with the accused and another man, Marvin Mathis, to sell electronic tablets. The victim was shot and died, and evidence tied the accused and Mathis to the scene through phone records, witness statements, and the accused’s own admissions. A third individual, Thompson, also described a plan to rob the victim.After conviction, Mathis was separately tried and found not guilty by reason of mental disease or defect under Connecticut law, with the court finding he lacked capacity to appreciate the wrongfulness of his conduct or conform it to legal requirements. The petitioner then filed for habeas corpus, arguing that Mathis’ acquittal constituted newly discovered evidence of the petitioner’s actual innocence, since a conspiracy requires the intent of at least two parties.The Superior Court denied the habeas petition, holding that Mathis’ acquittal was irrelevant to the petitioner’s innocence. The Appellate Court disagreed with the legal analysis, holding that evidence from Mathis’ trial should be considered, but still affirmed the denial, finding that a conspiracy could have existed between the petitioner and Thompson.On further appeal, the Connecticut Supreme Court held that while the Appellate Court applied the correct standard by considering aggregate evidence, it erred in concluding that Mathis’ acquittal clearly proved he could not have intended to conspire. The Supreme Court explained that an insanity acquittal does not necessarily negate specific intent, as the underlying findings were made by a preponderance of the evidence, not clear and convincing evidence. Thus, the Court affirmed the judgment, concluding the petitioner had not met the burden to prove actual innocence. View "Moon v. Commissioner of Correction" on Justia Law

A group of current and former warehouse workers employed by the defendants in Connecticut alleged that their employer failed to compensate them for time spent undergoing mandatory security screenings before leaving the workplace at the end of their shifts. The procedures required employees to pass through security—sometimes involving metal detectors, divesting tables, or X-ray machines—before being allowed to exit the premises. The length of these screenings varied, but employees were required to remain on the employer’s property during the process.After the workers filed a class action complaint in the Connecticut Superior Court, the defendants removed the case to the United States District Court for the District of Connecticut. The District Court granted summary judgment in favor of the employer, concluding that Connecticut’s wage laws were intended to align with federal law, specifically the Fair Labor Standards Act (FLSA) as amended by the Portal-to-Portal Act, and that, under federal law, such security screenings are not compensable. The workers appealed, and the United States Court of Appeals for the Second Circuit certified two questions to the Supreme Court of Connecticut regarding the interpretation of Connecticut’s wage laws.The Supreme Court of Connecticut held that, under the unambiguous language of Connecticut law, employers must compensate employees for all time required on the employer’s premises, including time spent undergoing mandatory security screenings. The Court further determined that Connecticut law does not recognize a de minimis exception that would allow employers to disregard small amounts of time as noncompensable. Thus, the Court answered the first certified question in the affirmative and the second in the negative, clarifying that Connecticut wage laws are more protective than federal law in this respect. View "Del Rio v. Amazon.com Services, Inc." on Justia Law

In this case, the defendant was charged with murder, burglary in the first degree, conspiracy to commit burglary in the first degree, and tampering with physical evidence, arising from the killing of a woman with whom he had an intimate relationship. The prosecution alleged that, following the discovery of the victim’s decomposed body, police conducted three interviews with the defendant. After waiving his Miranda rights in the second interview, he made incriminating statements and then said he was “done talking.” The next morning, while awaiting arraignment, the defendant initiated a third interview, again waived Miranda rights, and admitted to the killing.The trial took place in the Superior Court, judicial district of Waterbury, where a jury found the defendant guilty of all charges except conspiracy to commit tampering with physical evidence, which the court vacated at sentencing. The defense moved to suppress statements from the third interview, arguing the police had failed to clarify the defendant’s equivocal request for counsel under Connecticut law, and to suppress cell phone records as unsupported by probable cause and lacking particularity. The court denied these motions.On direct appeal, the Connecticut Supreme Court reviewed the trial court’s rulings. The Supreme Court held that any Miranda-based challenge to the admission of the second interview was waived by defense counsel, who had limited objections to the third interview only. Regarding the third interview, the Court found that rereading Miranda warnings and obtaining a written waiver sufficiently clarified the defendant’s equivocal request for counsel, satisfying State v. Purcell. The Court also determined the warrant for cell phone records was supported by probable cause and was sufficiently particular. The judgment of the Superior Court was affirmed. View "State v. Johnson" on Justia Law

A municipal tax collector initiated a bank execution action against an individual to collect unpaid personal property taxes owed by a business with which the individual was previously associated. The individual had moved to California years earlier and claimed that she never received notice of the tax debt or an opportunity to contest it, despite providing her new address to the tax collector. Previous bank executions had been initiated, but the individual continued to assert lack of notice. In the 2021 action, the trial court found that the tax collector failed to comply with statutory notice requirements and that the individual had not been afforded due process, leading the court to grant her exemption from the execution.Following the 2021 judgment, the tax collector withdrew its appeal and attempted a new bank execution after sending written demand to the individual's California address, but did not provide a new tax bill or opportunity to challenge it. The individual again moved for exemption. The Superior Court concluded that the new execution was a collateral attack on the previous judgment and was barred by doctrines of res judicata and collateral estoppel. The Appellate Court affirmed, finding that the issue of notice and opportunity to challenge the tax debt had been actually litigated and necessarily determined in the prior action.Upon review, the Connecticut Supreme Court held that collateral estoppel barred the municipal tax collector from relitigating whether it could execute on the individual's funds without first providing adequate notice and an opportunity to challenge the underlying tax debt. The Court determined that both independent, alternative grounds supporting the earlier judgment were entitled to preclusive effect and declined to create a public policy exception for municipal tax collection actions. The Supreme Court affirmed the judgment of the Appellate Court. View "Torrington Tax Collector, LLC v. Riley" on Justia Law

This case arose from a fire at a call center in Davao City, Philippines, in which twenty-nine people died. The plaintiffs, representing the estates of the deceased and other individuals, filed suit in Connecticut against a Connecticut company and two of its officers, alleging wrongful death and related claims. The decedents were employees of a Philippine company providing services for the defendant Connecticut company. The defendants argued that the Philippines was the proper forum for the dispute, stipulating that they would submit to Philippine jurisdiction, accept service, and waive certain defenses, including the statute of limitations, for a period of time.The Superior Court granted the defendants’ motion to dismiss on forum non conveniens grounds, finding that the Philippines was an adequate alternative forum. The trial court’s dismissal was conditional: if the Philippine courts declined jurisdiction, the plaintiffs could refile in Connecticut. The plaintiffs appealed, arguing that the Philippine courts would sua sponte dismiss the case as time-barred, and thus the Philippines was not an adequate alternative forum. The Appellate Court affirmed, concluding that the trial court applied the correct legal standard and properly considered the adequacy of the alternative forum.The Supreme Court of Connecticut reviewed the case, focusing on whether the trial court had properly assessed the adequacy of the Philippine forum. The court held that the trial court had applied the correct standard from Picketts v. International Playtex, Inc., meaningfully evaluating competing expert affidavits on Philippine law and the effect of the defendants’ stipulations. The Supreme Court concluded that the trial court did not rely solely on the defendants’ consent, but conducted the required assessment. The judgment of the Appellate Court was affirmed, upholding dismissal on forum non conveniens grounds, contingent on the defendants’ stipulation and the plaintiffs’ ability to reinstate the action if necessary. View "DeCicco v. Dynata, LLC" on Justia Law

The petitioner was convicted of conspiracy to commit robbery in the first degree, attempt to commit robbery in the first degree, and assault in the first degree, arising from the shooting of a pizza delivery driver. The prosecution’s case relied heavily on the testimony of an individual who was present with the petitioner on the night of the incident. This individual testified that the petitioner had used his cell phone to call and "case" various businesses, including the pizza restaurant employing the victim, to identify potential robbery targets. The defense argued that this individual was actually the perpetrator, not the petitioner.After conviction, the petitioner filed for a writ of habeas corpus in the Superior Court for the judicial district of Tolland, alleging ineffective assistance of counsel due to his trial attorney’s failure to investigate the key witness’s cell phone records and failure to interview additional potential alibi witnesses. The habeas court denied the petition. On appeal, the Appellate Court agreed that trial counsel’s performance was deficient for not investigating the cell phone records but determined, by a majority, that the petitioner had not shown sufficient prejudice resulting from this deficiency. The Appellate Court affirmed the habeas court’s judgment.Upon further appeal, the Supreme Court of Connecticut reviewed whether the petitioner was prejudiced by trial counsel’s failure to investigate the cell phone records. The Supreme Court held that there was a reasonable probability that, had the records been investigated and introduced at trial, the jury would have had reasonable doubt about the petitioner’s guilt. The cell phone records would have undermined the credibility of the key witness’s account and a corroborating police officer’s testimony, and supported the defense theory of third-party culpability. The Supreme Court reversed the Appellate Court’s judgment, directed that the habeas petition be granted, the convictions vacated, and a new trial ordered. View "Grant v. Commissioner of Correction" on Justia Law

The defendant was charged with multiple counts of sexual assault in the first degree and risk of injury to a child, stemming from multiple incidents of sexual abuse against two minor victims who attended an in-home day care operated by the defendant’s wife in New Haven. The alleged abuse occurred between 2007 and 2012, when the victims were approximately three to eight years old. Each count of sexual assault was predicated on multiple, separate instances of specific sexual acts committed by the defendant. Following police investigations in 2019 and subsequent arrest in 2020, the defendant was tried on these charges.At trial in the Superior Court for the judicial district of New Haven, the prosecution presented evidence of several distinct incidents of sexual abuse. The trial judge provided the jury with a specific unanimity instruction for each count, requiring jurors to unanimously agree that the defendant committed at least one specific instance of the charged conduct in order to find him guilty on any particular count. The jury found the defendant guilty on all counts of sexual assault and risk of injury to a child, and the court sentenced him to a total effective sentence of twenty-five years, with execution suspended after twenty-one years and ten years of probation.On direct appeal to the Connecticut Supreme Court, the defendant argued that his federal constitutional right to a unanimous jury verdict was violated because the trial court did not require the jury to answer special interrogatories regarding unanimity on each alleged incident, despite providing proper unanimity instructions. The Connecticut Supreme Court held that the constitution does not require special interrogatories in addition to specific unanimity instructions for counts charging multiple instances of conduct. The court affirmed the judgments of conviction. View "State v. Carlos G." on Justia Law

On the evening of November 10, 2021, the defendant unlawfully entered a residence in West Hartford, Connecticut, where multiple individuals were present, including his ex-girlfriend and her family. The defendant shot one of the occupants, Dyquan Daniels, in the face and threatened another before fleeing. Police apprehended the defendant shortly afterward and found gunshot residue on his hand. The prosecution charged the defendant with several offenses, including home invasion, assault in the first degree by discharge of a firearm, criminal possession of a firearm, threatening in the second degree, and two counts of risk of injury to a child.The case was tried before the Superior Court in the judicial district of Hartford. The state’s operative information charged the defendant generally under the home invasion statute, with language tracking one specific subdivision, but did not specify a particular subsection or subdivision. During trial, defense counsel argued a third-party culpability defense, suggesting someone else committed the shooting. The trial court instructed the jury on home invasion using a different subdivision than the one tracked in the information, requiring proof that the defendant was armed with a deadly weapon. The jury found the defendant guilty on all counts.The Connecticut Supreme Court reviewed the appeal. It held that the trial court did not commit plain error in its instructions because the defendant received adequate notice that he could be convicted under either subdivision of the home invasion statute, as the facts alleged and the related counts necessarily involved being armed with a deadly weapon. The court also found no double jeopardy violation, determining that home invasion and assault in the first degree each require proof of distinct elements. The judgment of conviction was affirmed. View "State v. Christon" on Justia Law

The plaintiff was involved in a car accident with the defendant, after which he sought damages for the diminished value and loss of use of his vehicle, alleging the accident was caused by the defendant’s negligence. The defendant’s insurer paid the full property damage coverage limit to the plaintiff’s insurer, based on the assertion that the plaintiff had been made whole. The plaintiff then amended his complaint to allege that his insurer was unjustly enriched for accepting the payment and exhausting the defendant’s coverage before the plaintiff was fully compensated, in violation of the make whole doctrine.The case was brought in the Superior Court for the judicial district of Hartford, which dismissed the unjust enrichment claim against the insurer, finding it was not ripe for adjudication. The court reasoned that the plaintiff’s claim depended on the outcome of his negligence action against the defendant. The plaintiff appealed, and the Connecticut Appellate Court affirmed the dismissal, concluding the unjust enrichment claim would only become ripe after the plaintiff obtained a judgment against the defendant and exhausted collection efforts, because the injury was contingent on whether and to what extent the plaintiff could recover and on the defendant’s ability to satisfy a judgment.On review, the Supreme Court of Connecticut held that the Appellate Court incorrectly affirmed the dismissal on ripeness grounds. The Supreme Court ruled that a claim based on premature subrogation in violation of the make whole doctrine is ripe for adjudication even before a judgment against the tortfeasor is obtained, because the alleged injury—violation of the plaintiff’s priority right to the defendant’s insurance coverage—had already occurred. The court also found the plaintiff had standing to assert his claim. The Supreme Court reversed the Appellate Court’s judgment and remanded for further proceedings. View "Orlando v. Liburd" on Justia Law