Justia Connecticut Supreme Court Opinion Summaries

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

The defendant was charged with criminal possession of a firearm or ammunition and criminal violation of a protective order. These charges stemmed from two prior cases involving allegations of sexual assault in the fourth degree and risk of injury to a child, both concerning a minor family member. In each prior case, the Superior Court issued protective orders requiring the defendant to surrender firearms and ammunition. In 2022, the defendant was arrested for allegedly possessing firearms or ammunition in violation of those protective orders.After the 2022 arrest, the defendant moved to dismiss the new charges, arguing that the protective orders were not issued "in a case involving the use, attempted use or threatened use of physical force" as required by Connecticut General Statutes § 53a-217(a)(4)(A), since the underlying offenses did not explicitly include use of physical force as an element. The Superior Court denied the motion to dismiss. The defendant then entered a conditional plea of nolo contendere to one count each of criminal possession of a firearm or ammunition and criminal violation of a protective order. The state entered a nolle prosequi as to the remaining charges. The defendant appealed, and the case was transferred from the Appellate Court to the Connecticut Supreme Court.The Connecticut Supreme Court affirmed the judgment. It held that the phrase "a case involving" in § 53a-217(a)(4)(A) is broadly inclusive and refers to the overall proceeding, not just the elements of the charged offense. Therefore, protective orders issued during prosecutions for sex offenses, where the use or threat of physical force or superior physical strength was present in any aspect, satisfy the statute. The court also rejected the defendant’s claim that the statute was unconstitutionally vague as applied, finding it provided sufficient guidance. Finally, the court determined that the defendant’s Second Amendment challenge to the validity of the protective orders was barred by the collateral bar rule. View "State v. Enrrique H." on Justia Law

The defendant was involved in a fatal shooting during a drug transaction in Hartford, Connecticut. He testified at trial that he acted in self-defense, claiming the victim drew a gun on him during a dispute. However, other witnesses contradicted this account, and no gun was found on or near the victim. After the shooting, the defendant fled the scene and did not report the incident to the police. He was later arrested and charged with murder.The case was tried before the Superior Court in the judicial district of Hartford. At trial, the defendant testified in his own defense. The prosecutor, with approval from the trial court, cross-examined the defendant regarding his failure to report to police that he had acted in self-defense prior to his arrest. The defense objected, arguing that the questioning infringed upon the defendant’s right to remain silent, but the trial court overruled the objection, reasoning that, by testifying, the defendant waived his Fifth Amendment right regarding silence and that his failure to report was inconsistent with a claim of self-defense. The jury found the defendant guilty of murder, and he was sentenced to fifty years in prison.On direct appeal to the Supreme Court of Connecticut, the defendant argued that the trial court committed plain error by allowing the prosecutor to cross-examine him about his prearrest silence. The Supreme Court of Connecticut held that the trial court did not commit plain error because established case law allows impeachment using a defendant’s prearrest, pre-Miranda silence, particularly when the defendant testifies and claims self-defense. The Court concluded that the circumstances did not present an obvious or egregious error requiring reversal. The judgment of conviction was affirmed. View "State v. Thorpe" on Justia Law

The case involved a defendant who, while driving a sport utility vehicle (SUV) without a license, struck and fatally injured a pedestrian at an intersection in Waterbury, Connecticut. The defendant fled the scene without stopping. Several miles away, after the SUV broke down and partially blocked a residential driveway, the defendant, with the help of the homeowner and a taxi driver, pushed the damaged SUV into the driveway, leaving it at the front of other vehicles with its damaged front end fully visible from the street. The defendant did not attempt to hide the SUV further, nor did he inform the homeowner of the accident.A jury in the Superior Court for the judicial district of Waterbury found the defendant guilty of evasion of responsibility in the operation of a motor vehicle and tampering with physical evidence, based on the state’s theory that the defendant concealed the SUV to impair its availability in a criminal investigation. The Appellate Court affirmed the convictions, holding that a rational juror could find the act of concealment based on the context and circumstances, including the defendant’s flight from the scene and the temporary abandonment of the SUV in a private driveway.On further review, the Supreme Court of Connecticut concluded that the evidence was insufficient to establish concealment under General Statutes § 53a-155 (a). The court held that simply leaving the SUV in a visible spot at the front of a driveway, where its damage was apparent from the street, did not constitute concealment as required by the statute. The Supreme Court reversed the tampering conviction, directing the trial court to enter a judgment of acquittal on that charge and leaving resentencing, if any, to the trial court’s discretion. The remaining conviction was affirmed. View "State v. Bolden" on Justia Law

A defendant was convicted of multiple sexual offenses arising from the abuse of a minor, J, who lived with him and her mother over several years. The victim alleged that the defendant, who acted as a father figure, committed various acts of sexual, physical, and emotional abuse while the mother was at work. After the defendant was incarcerated for a separate domestic dispute, J disclosed the abuse to her mother, which eventually led to a police report and a forensic interview at a child advocacy center. Subsequently, a pediatrician conducted a medical examination and relied on the forensic interview report to obtain a history of the alleged abuse. The physical exam results were normal and did not confirm or refute the allegations.The case was tried in the Superior Court in the judicial district of New Britain. During trial, the state sought to admit statements J made during her forensic interview through the testimony of the interviewer, arguing these were admissible under the medical diagnosis and treatment exception to the hearsay rule. The defense objected, contending the interview lacked a medical purpose. The trial court overruled the objection and admitted the statements. The jury found the defendant guilty on all counts, and the court imposed a substantial prison sentence. The defendant appealed, raising two main issues: the admission of the forensic interview statements as hearsay, and the denial of a special jury instruction on child witness credibility.The Connecticut Supreme Court reviewed the appeal. It clarified that, for statements to be admissible under the medical treatment exception, the declarant must be motivated, at least in part, by a desire to obtain medical diagnosis or treatment, and the statements must be reasonably pertinent to that end. The Court found the trial court abused its discretion in admitting the forensic interview statements because there was insufficient evidence that J understood the interview had a medical purpose. However, the Court concluded this error was harmless since the evidence was cumulative of J’s testimony and not emphasized by the prosecution. The Court further held the trial court did not abuse its discretion in denying a special child credibility instruction, and it declined to modify its approach to such instructions. The judgment of conviction was affirmed. View "State of Connecticut v. Giovanni D." on Justia Law

The case involved a fatal shooting that followed a car accident in Hartford, Connecticut. The defendant, after colliding with the victim’s vehicle, agreed to pay for the damages and arranged to meet the victim later that day. Surveillance footage and eyewitness accounts linked the defendant to the scene, describing his distinctive clothing and actions. Evidence showed the defendant met with the victim, shot him multiple times, and fled the scene. Forensic analysis detected gunshot residue on the defendant’s clothing, and cellphone data further corroborated his involvement. The defendant was subsequently arrested and charged with murder and criminal possession of a firearm.At trial in the Superior Court for the judicial district of Hartford, the jury found the defendant guilty of murder, and the court found him guilty of criminal possession of a firearm. The defendant appealed directly to the Connecticut Supreme Court, raising several unpreserved constitutional claims. He argued that his right to confrontation was violated when the State’s gunshot residue expert testified based on data and notes from a nontestifying analyst, and when the prosecutor elicited testimonial hearsay on cross-examination. He also alleged prosecutorial impropriety for introducing facts not in evidence during cross-examination.The Connecticut Supreme Court held that the claim regarding the expert’s reliance on the nontestifying analyst’s materials failed because the record was inadequate to determine whether those materials were testimonial. The court declined to adopt the State’s proposed rule barring all unpreserved confrontation claims and reaffirmed that such claims may still be reviewed if the record is sufficient. The court further held there was no confrontation clause violation or prosecutorial impropriety regarding the cross-examination, as the questions did not introduce hearsay or inadmissible evidence. The judgment of conviction was affirmed. View "State of Connecticut v. Bester" on Justia Law

A five-year-old child and her mother, recently arrived from the Dominican Republic, were staying with family in New Britain, Connecticut. The defendant, who was married to the mother's niece, lived in the same apartment. On New Year's Eve, the defendant sexually assaulted the child. Later that evening at a family party, the child told her mother that the defendant had kissed her, and after further questioning, disclosed more details of the assault. The next day, the mother confronted the defendant, who made incriminating admissions both in person and via text. Police interviewed the defendant at the station after he voluntarily agreed to meet and requested a Spanish-speaking detective. During the interview, which was conversational and not confrontational, the defendant confessed to inappropriate sexual conduct.The Superior Court, Judicial District of New Britain, denied the defendant’s pretrial motion to suppress his statements to police, finding he was not in custody for Miranda purposes. At trial, the court admitted the child’s statements to her mother under the spontaneous utterance exception to hearsay, and limited the testimony of the defense expert regarding the U visa program, which provides immigration benefits to victims of certain crimes who cooperate with law enforcement. The jury convicted the defendant of sexual assault in the first degree and risk of injury to a child.On direct appeal to the Connecticut Supreme Court, the defendant argued the trial court erred in denying his suppression motion, admitting the victim’s hearsay statements, and restricting expert testimony, and further sought review of confidential personnel records of one detective. The Connecticut Supreme Court held that the trial court properly denied the suppression motion, as the defendant was not in custody. The admission of the child’s statements was error but harmless, given other strong evidence. The limitations on the expert’s testimony did not deny due process or affect the verdict. Review of the confidential records revealed no material requiring disclosure. The conviction was affirmed. View "State of Connecticut v. Lazaro D." on Justia Law

A group of retired law enforcement officers who had worked for a Connecticut town sought a court declaration that they were entitled to receive contributions to their health savings accounts (HSAs) from the town in the same manner as currently employed police officers. The retirees based their claim on a pension agreement negotiated by the town and their union, which provided that retirees would receive health insurance coverage, including deductibles, “in effect for active Police Officers.” After these retirees left their positions, a new collective bargaining agreement was executed that changed the town’s insurance plan to a high deductible health plan and required the town to contribute 50% of the deductible amount to the HSAs of active police officers. The retirees, now participating in the same insurance plan, did not receive these contributions.The Superior Court for the judicial district of New London found in favor of the retirees, concluding that the pension agreement entitled them to the same HSA contributions as active officers. The court awarded damages accordingly. The Appellate Court affirmed, reasoning that the effect of the HSA contributions was to lower the deductible for active officers, and that the retirees were entitled to equal treatment under the pension agreement.On appeal, the Connecticut Supreme Court reviewed whether these HSA contributions constituted “coverage” or “deductibles” under the relevant pension agreement. The court held that the ordinary meaning of “coverage” and “deductible” did not include HSA contributions, which are distinct from the insurance policy’s terms and can be used for a variety of purposes. The court further noted that extrinsic evidence, including subsequent collective bargaining agreements, confirmed that the contracting parties did not intend HSA contributions for retirees. The Supreme Court reversed the Appellate Court’s judgment and directed that judgment be entered for the town. View "Duso v. Groton" on Justia Law

A seventeen-year-old defendant was charged with murder after the shooting death of a victim in a Bridgeport housing complex stairwell. Surveillance footage showed the defendant leading the victim into the building and exiting alone minutes later, covering his face with a mask. The victim was later found naked and bleeding outside the basement door, having been shot six times. Police investigation led to a search of the defendant’s home, where a .45 caliber pistol and matching ammunition were found in his bedroom. The defendant, interviewed at home in the presence of his legal guardian, admitted to owning the gun and being with the victim but denied involvement in the shooting. Nineteen minutes into the interview, he invoked his right to remain silent, but questioning continued. The defendant was later located in Florida and returned to Connecticut for trial.In the Superior Court for the judicial district of Fairfield, the defendant moved to suppress statements made during the police interview, arguing he had not knowingly and voluntarily waived his Miranda rights. The court found, under the totality of the circumstances, that the waiver was valid, considering the defendant’s age, education, prior experience with law enforcement, and the presence of his guardian. The court suppressed only statements made after the defendant invoked his right to remain silent. The jury convicted the defendant of murder, and he was sentenced to forty-five years’ incarceration.On appeal to the Connecticut Supreme Court, the defendant challenged the validity of his Miranda waiver, sought greater protection under the state constitution, alleged prosecutorial impropriety, and objected to a consciousness of guilt jury instruction. The Supreme Court held that the waiver was knowing, intelligent, and voluntary, declined to adopt a rule requiring consultation with an interested adult before a juvenile’s waiver, found no prosecutorial impropriety, and determined any error in the consciousness of guilt instruction was harmless. The judgment was affirmed. View "State v. Cooper" on Justia Law

In 1984, four women in Connecticut were robbed and sexually assaulted in their homes by an unknown assailant. The perpetrator blindfolded, restrained, and threatened each victim, then stole items before leaving. Police collected physical evidence from the crime scenes, but DNA testing was not available at the time. Years later, advances in forensic science allowed the state laboratory to develop DNA profiles from the evidence, which were uploaded to the Combined DNA Index System (CODIS). In 2020, a private forensic company provided investigative leads, ultimately implicating the defendant. Police lawfully collected trash from the defendant’s residence, including a belt, and submitted it for DNA analysis without a warrant. The DNA extracted from the belt matched the crime scene profiles. Police then obtained a warrant for a confirmatory DNA sample, which further implicated the defendant.The defendant was charged in the Superior Court for the judicial district of Hartford with eight counts of kidnapping in the first degree. At trial, the court instructed the jury on the elements of kidnapping, including the factors from State v. Salamon, which help determine whether restraint exceeded what was necessary for the underlying crimes. The next day, the court provided the jury with a flowchart outlining the kidnapping elements, but the chart omitted reference to the Salamon factors. The jury found the defendant guilty on all counts, and he was sentenced to seventy-two years in prison.On appeal to the Connecticut Supreme Court, the defendant argued that the warrantless collection and analysis of his DNA from the discarded belt violated his rights under the Fourth Amendment and the Connecticut Constitution, and that the omission of the Salamon factors from the flowchart misled the jury. The Connecticut Supreme Court held that neither the collection nor the analysis of DNA from the discarded belt constituted a search under the Fourth Amendment or the state constitution when performed for identification purposes only. The court also found that the jury was not misled by the flowchart, as the full instructions included the Salamon factors and the jury was properly directed to rely on those instructions. The judgment of conviction was affirmed. View "State v. Sharpe" on Justia Law