Justia Connecticut Supreme Court Opinion Summaries

The petitioner was convicted of murder and conspiracy to commit murder in connection with the shooting death of a woman who was pregnant with his child. After unsuccessfully convincing the victim to have an abortion, he conspired with a close friend to kill her. The friend ultimately fired the fatal shot. Weeks later, the friend confessed to a mutual acquaintance, who later served as a key prosecution witness. That witness also participated in a subsequent robbery with the friend, using the same firearm as in the murder. Information from the robbery investigation helped implicate both the friend and the petitioner in the murder. At trial, the witness testified that he had not been promised any deals or consideration for his testimony, although he later alluded to unspecified “considerations.” His defense attorney also testified, indicating there would be some consideration for truthful testimony but denying any formal agreement.The habeas court, Superior Court in the judicial district of Tolland, denied the petitioner’s request for a writ of habeas corpus. The court found that the witness’s testimony about the scope of any agreement was truthful and that the jury had been made aware that something would be done in exchange for his testimony. It further concluded that any ambiguity was clarified by testimony from the witness’s defense attorney, who explained that consideration would be given but no specific deal existed.The Supreme Court of Connecticut reviewed the case and held that the prosecutor violated Napue v. Illinois by eliciting false or substantially misleading testimony regarding the existence and nature of an agreement with the witness, failing to correct those misimpressions, and relying on the misleading testimony in closing argument. The court found these violations were material, as there was a reasonable likelihood they affected the jury’s verdict. The judgment of the habeas court was reversed, and the case remanded with instructions to grant the habeas petition, vacate the conviction, and order a new trial. View "Bryan v. Commissioner of Correction" on Justia Law

The plaintiff, a limited partnership, initiated an action in 2019 against the State of Connecticut and its Commissioner of Energy and Environmental Protection, alleging unreasonable delays in processing applications for reimbursement under the underground storage tank petroleum clean-up program. The plaintiff sought a writ of mandamus to compel payment for approved claims and adjudication of pending claims, as well as damages for alleged constitutional violations and unlawful taking of property.The Superior Court dismissed the action for lack of subject matter jurisdiction, citing sovereign immunity. On appeal, the Connecticut Appellate Court reversed the dismissal as to the mandamus claim and remanded for further proceedings, but affirmed dismissal of the damages claims. Following remand, the plaintiff amended its complaint to seek only a writ of mandamus for payment of approved claims. The trial court denied this request, finding the plaintiff did not show a complete and immediate right to payment. The Appellate Court affirmed, and the plaintiff was granted certification to appeal to the Supreme Court of Connecticut.After certification was granted, the legislature enacted Public Act 25-168, which cancelled all applications under the program, transferred remaining funds to the state’s general fund, and repealed the statutory scheme governing the program. The Supreme Court of Connecticut concluded that these legislative actions rendered the plaintiff’s appeal moot, as no practical relief could be granted. The court dismissed the appeal and vacated the judgments of the Appellate Court and the trial court pertaining to the writ of mandamus, but declined to vacate prior judgments in unrelated claims from earlier proceedings. View "Aldin Associates Ltd. Partnership v. State" on Justia Law

The case involved the fatal shooting of a victim in Stamford, Connecticut. Following the incident, police investigation placed the defendant near the crime scene through surveillance footage. A search of the defendant’s home yielded clothing matching what he was seen wearing on the night of the murder. Although no firearm was recovered, the state tested the clothing for primer gunshot residue (pGSR). At trial, a forensic science examiner testified that particles “commonly associated with” pGSR were found on the clothing, and her report was admitted into evidence. Other evidence included cell phone records and witness testimony placing the defendant near the scene but did not directly tie him to possessing a firearm.Prior to trial in the Superior Court for the judicial district of Stamford-Norwalk, the defendant moved to preclude the pGSR evidence and requested a hearing under State v. Porter to determine the reliability of the scientific methodology behind the pGSR analysis. The trial court denied the request, ruling that pGSR analysis was a well-established area of forensic science and therefore did not require a Porter hearing. The defendant was convicted by a jury of murder, and he appealed directly to the Connecticut Supreme Court.The Supreme Court of Connecticut held that the trial court abused its discretion by refusing to conduct a Porter hearing solely because it viewed pGSR analysis as well established, without considering new evidence and advancements in the field that could affect its reliability. The Court emphasized that trial judges must exercise their gatekeeping function by considering whether new scientific developments cast doubt on previously accepted methodologies. Finding that this error was harmful—since the pGSR evidence was central to the state’s case and could have influenced the verdict—the Supreme Court reversed the conviction and ordered a new trial. View "State v. Sellers" on Justia Law

The defendant was convicted of murder following a retrial in 1981 and sentenced to an indeterminate term of 25 years to life, with a mandatory minimum of 25 years. The underlying facts involved the killing of a friend’s mother during a burglary and a subsequent fatal car crash. The defendant’s conviction was affirmed on direct appeal and collateral review. While incarcerated, the defendant applied for parole in 2013 and 2019, and for a commutation of his sentence in 2021; all applications were denied. He then filed a motion for sentence modification, citing his intellectual disability, youth at the time of the offense, remorse, age, physical incapacity, and low risk of recidivism as grounds for good cause. The trial court denied the motion, finding the defendant had not established good cause.On appeal, the Connecticut Appellate Court affirmed the trial court’s decision, holding that it was proper to consider the Board of Pardons and Paroles’ prior denials of parole and commutation as part of the sentence modification inquiry. The Appellate Court also noted that the trial court had considered other relevant factors, such as the seriousness of the offense, the impact on the victims, and the defendant’s disciplinary record while incarcerated.The Supreme Court of Connecticut reviewed the case on certification. It held that a trial court may consider prior decisions of the Board of Pardons and Paroles in ruling on a motion for sentence modification, as such information falls within the broad scope of relevant sentencing information. The Court found no abuse of discretion or due process violation, as the trial court’s reliance on the board’s denials was not impermissibly speculative and was only one factor among several considered. The judgment of the Appellate Court was affirmed. View "State v. Toste" on Justia Law

The property at issue has a long history of agricultural use, initially for tobacco farming and processing. This activity predates the Town of Suffield’s zoning regulations, making it a legal nonconforming use. In 2019, the plaintiff obtained state approval to cultivate and process hemp at the property, which was determined by local officials to fall within the scope of the existing nonconforming tobacco use. Following Connecticut’s legalization of recreational cannabis in 2021, the plaintiff sought a zoning determination that cannabis cultivation and processing would also be a lawful continuation of the existing nonconforming use. The zoning enforcement officer denied this request, citing distinct licensing and regulatory requirements for hemp and cannabis.The Zoning Board of Appeals of the Town of Suffield upheld the zoning officer’s decision, relying primarily on the legal and regulatory distinctions between hemp and cannabis. The plaintiff appealed to the Superior Court for the judicial district of Hartford. The trial court applied the factors from Zachs v. Zoning Board of Appeals to assess whether the proposed cannabis use impermissibly expanded the scope of the nonconforming use. The court found that the regulatory differences were relevant but not dispositive and concluded that cannabis cultivation and processing were sufficiently similar to the existing hemp operation to constitute a lawful continuation of the nonconforming use. The trial court reversed the board’s decision.The Supreme Court of Connecticut reviewed the case. It held that a difference in state licensing or regulatory schemes is relevant but not determinative in assessing whether a proposed use constitutes an impermissible expansion of a nonconforming use. Instead, courts must conduct a fact-intensive inquiry, considering the nature, purpose, character, and effects of the use. Here, the Supreme Court found no evidence that cannabis cultivation and processing would materially change the property’s use or impact the neighborhood. Thus, it affirmed the trial court’s judgment, allowing the cannabis operation as a lawful continuation of the nonconforming use. View "Lasa Extract, LLC v. Zoning Board of Appeals" on Justia Law

A property owner of a rental income-producing property in Greenwich, Connecticut, failed to timely submit a required income and expense form to the municipal assessor. The assessor had mailed both a demand for information and the prescribed form in April 2020 to the last known address on record, which was the property manager’s former address. The property owner did not receive this mailing because it had changed addresses in 2016 but had not directly informed the assessor. Later, when a forwarded tax bill prompted the owner to update its address, a reminder notice was sent to the correct address, but it arrived after the filing deadline. The owner ultimately submitted the form late, and the assessor imposed a statutory penalty increasing the property’s assessed value by 10 percent.The property owner appealed the penalty to the town’s board of assessment appeals, which upheld the penalty. The owner then appealed to the Superior Court, arguing it should not be penalized because it had not actually received the form before the deadline. The Superior Court found for the town, reasoning that timely mailing to the last known address satisfied the statutory requirement and that the owner bore responsibility for ensuring its address was up to date.The owner appealed to the Connecticut Appellate Court, which affirmed the trial court’s judgment. The owner then sought further review from the Connecticut Supreme Court. The Supreme Court held that the statutory requirement for the assessor to provide the form is satisfied by mailing it to the property owner’s last known address, regardless of actual receipt. The Court found that the statute does not require assessors to ensure actual receipt and that fundamental fairness is met by using the last known address. The judgment of the Appellate Court was affirmed. View "Greenwich Retail, LLC v. Greenwich" on Justia Law

The petitioner was convicted of murder after a jury trial in which a key witness, who had been involved in the crime and was separately charged, testified for the state. Before trial, the petitioner’s counsel inquired whether any deal or understanding of leniency existed between the state and the witness, but the prosecutor denied there were any assurances. During cross-examination, the witness denied having been promised any benefit in exchange for his testimony but indicated he was hoping his cooperation would help him at sentencing. Shortly after the petitioner’s conviction, the witness received a notably lenient sentence in his own criminal case, pursuant to a plea agreement.The petitioner subsequently filed for habeas corpus, alleging that the state had failed to disclose an informal cooperation agreement with the witness and had allowed the witness to deny such an agreement under oath, thus violating his due process rights under Napue v. Illinois. At the habeas trial in the Connecticut Superior Court, the witness, his defense counsel, and three prosecutors all testified that there was no cooperation agreement. The habeas court found no such agreement existed and denied the petition. The Connecticut Appellate Court affirmed this judgment.On appeal, the Supreme Court of Connecticut clarified that prosecutors have a duty to correct false or substantially misleading testimony about both formal and informal cooperation agreements, including those that are implied, unwritten, or tacit. The court held that, while lenient treatment alone does not prove an agreement, courts must consider whether prosecutors’ conduct created an expectation of leniency and whether the witness acted on that expectation. Because the record was insufficient to determine whether all parties understood what constitutes an informal agreement in this context, the Supreme Court remanded the case to the habeas court for further factual findings, while retaining jurisdiction for a final decision on the appeal. View "Moore v. Commissioner of Correction" on Justia Law

The petitioner was convicted of felony murder, first-degree robbery, and conspiracy to commit robbery following an incident in Hartford where the victim was robbed of jewelry and fatally shot. The State’s case included testimony from two eyewitnesses and a police sergeant who presented cell site location information (CSLI) derived from the petitioner’s cell phone records. This data was used to create a time-lapse video that depicted a human silhouette purportedly tracing the movements of the petitioner’s phone between the crime scene, a pawn shop, and other relevant locations. The video and supporting testimony were admitted without objection, and the prosecution relied heavily on them during closing arguments.On direct appeal, the Connecticut Appellate Court affirmed the conviction, concluding that trial counsel’s failure to object to the CSLI evidence or request a Porter hearing was a strategic decision, and the petitioner’s unpreserved evidentiary claims were unreviewable. The Connecticut Supreme Court later affirmed that decision. While the appeal was pending, the petitioner filed for habeas relief in the Superior Court, arguing ineffective assistance of counsel, specifically that his trial attorney failed to challenge the admissibility or accuracy of the CSLI evidence and the time-lapse video.The Connecticut Supreme Court, reviewing the habeas court’s judgment, held that trial counsel performed deficiently by not challenging the misleading GeoTime video, which misrepresented the capabilities of CSLI technology by depicting precise movements unsupported by the underlying data. The Court found that this failure prejudiced the petitioner, as the State’s case was not strong absent the contested evidence, and the misleading video was the prosecution’s most persuasive link to the crime. Consequently, the Supreme Court affirmed the habeas court’s decision vacating the conviction and ordering a new trial. View "Turner v. Commissioner of Correction" on Justia Law

Underwood Towers Limited Partnership leased land from the city of Hartford to build apartment buildings and financed the project with a mortgage loan. After defaulting, Underwood executed additional notes and a second mortgage in favor of HUD. Following further defaults and transfers, LPP Mortgage Inc. acquired the second mortgage and notes but did not receive the original of one note—only a lost note affidavit. LPP Mortgage then brought a foreclosure action, seeking not only to foreclose the mortgage but also damages against Underwood and its management agent, CDC Management Corporation.The Superior Court, Complex Litigation Docket, denied Underwood and CDC’s motion to dismiss, ruling that LPP Mortgage had standing to foreclose as the owner of the debt, even without possession of the lost note, relying on New England Savings Bank v. Bedford Realty Corp. Judgment of strict foreclosure and damages was entered. On appeal, the Connecticut Appellate Court affirmed, concluding that LPP Mortgage had standing to pursue foreclosure as the debt owner, despite not being able to enforce the note under the UCC. The case was remanded for setting new law days. After remand, Underwood and CDC again moved to dismiss, arguing that the Connecticut Supreme Court’s later decision in Bank of New York Mellon v. Tope changed the law, requiring possession of the note to foreclose.The Connecticut Supreme Court reviewed the case after transfer from the Appellate Court. The Court held that res judicata barred Underwood and CDC from relitigating LPP Mortgage’s standing, as the issue had already been fully litigated and decided by the Appellate Court. The Supreme Court further held that Bank of New York Mellon v. Tope did not overrule Bedford Realty Corp., and thus the law had not changed. The trial court’s denial of the motions to dismiss was affirmed, and the case was remanded for further proceedings. View "LPP Mortgage Ltd. v. Underwood Towers Ltd. Partnership" on Justia Law

The case centers on the tragic death of a young woman who was murdered by her former romantic partner shortly after he was discharged from a psychiatric hospital. The partner had previously expressed homicidal ideations toward her, both to medical staff and law enforcement, and was involuntarily committed under Connecticut law for psychiatric disabilities and being a danger to others. After a brief stay, he was discharged from the psychiatric facility with no further supervision or warning provided to either the victim or law enforcement. The plaintiff, administratrix of the victim’s estate, sued the mental health care provider, alleging both ordinary negligence and medical malpractice for failing to protect the victim from a known risk.The Superior Court in the judicial district of Hartford granted the provider’s motion to strike, finding that all claims sounded in medical malpractice since the alleged negligence involved medical judgment relating to diagnosis and treatment. Relying on Jarmie v. Troncale, the court concluded that, under Connecticut law, medical malpractice actions can only be brought by patients, and since the victim was not a patient, the claims were barred. The court also determined that Connecticut does not recognize gross negligence as a separate cause of action.On appeal, the Supreme Court of Connecticut reviewed the trial court’s decision. The Supreme Court held that some allegations did implicate medical malpractice and were barred, but others, liberally construed, sounded in ordinary negligence. These included claims that the provider actually knew of a substantial risk of imminent harm to an identifiable third party and failed to take reasonable steps to protect or warn her. The Court, for the first time, recognized a limited duty: a mental health care provider who knows a patient poses a substantial risk of imminent harm to an identifiable third party must take reasonable steps to protect that party, which may include warning or controlling the patient. The judgment was reversed in part and remanded for further proceedings on the ordinary negligence claims. View "Ashworth v. Branford" on Justia Law