Justia Connecticut Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the habeas court granting Petitioner's petition for writ of habeas corpus after determining that Petitioner had suffered prejudice as a result of the ineffective assistance of his trial counsel, holding that there was no error.In granting habeas relief, the habeas court determined that Petitioner's trial counsel failed to provide Petitioner with professional advise and assistance during pretrial plea negotiations and that Petitioner would have accepted the trial court's pretrial plea offer but for the ineffective assistance of Petitioner's trial counsel. The Supreme Court affirmed, holding that the habeas court did not err in concluding that Petitioner had fulfilled his burden of establishing prejudice. View "Barlow v. Commissioner of Correction" on Justia Law

The Supreme Court reversed in part the judgment of the trial court awarding Plaintiff $200,309 in damages for Defendants' breach of a lease agreement, holding that the trial court improperly allocated the burden of proof as to mitigation in determining the damages award.At issue in this appeal was how the executive orders issued by Governor Ned Lamont during the earliest months of the COVID-19 pandemic affected the enforceability of a commercial lease agreement for premises that Defendants leased from Plaintiff. Both parties appealed from the judgment of the trial court awarding Plaintiff damages. The Supreme Court reversed in part, holding that the trial court (1) did not err in determining that the economic effects of the executive orders did not relieve Defendants of their obligations under the lease agreement; but (2) improperly relieved Defendants of their burden of proving that Plaintiff's efforts were commercially unreasonable under the circumstances, thus necessitating a new damages hearing. View "AGW Sono Partners, LLC v. Downtown Soho, LLC" on Justia Law

The Supreme Court reversed the judgment of the trial court accepting Defendant's plea of nolo contendere to robbery in the first degree and assault in the first degree and sentencing Defendant to an aggregate sentence of ten years' imprisonment, holding that a John Doe arrest warrant was invalid and could not commence prosecution for purposes of satisfying the statute of limitations.On appeal, Defendant argued that the John Doe arrest warrant that identified the suspect on the basis of a general physical description and several mixed partial DNA profiles to which the suspect may not have been a contributor and that did not state the probability that a random person would match any of the profiles did not satisfy the particularity requirement of the Fourth Amendment for purposes of commencing a prosecution within the applicable statute of limitations. The Supreme Court agreed, holding that, to satisfy the Fourth Amendment's particularity requirement, the affidavit accompanying a John Doe DNA arrest warrant application must contain information assuring the judicial authority issuing the warrant that the DNA profile identifies the person responsible for the crime on the basis of his or her unique DNA profile and should include information as to the statistical rarity of that DNA profile. View "State v. Police" on Justia Law

The Supreme Court exercised its supervisory authority to require that a trial court either canvass the defendant or, in certain circumstances, inquire of defense counsel directly to determine whether the defendant was properly advised regarding the waiver of his right to testify.Defendant was convicted of one count of sexual assault in the first degree following a jury trial at which he did not testify. On appeal, Defendant argued that defense counsel's representation that Defendant had waived his right to testify was insufficient to constitute a waiver of that right. The Supreme Court affirmed, holding (1) the constitution does not require that a defendant personally assert the waiver of his constitutional right to testify on the record; but (2) an on-the-record canvass of a defendant is the best practice to ensure that the defendant's waiver of his right to testify is made knowingly, intelligently and voluntarily. View "State v. Morel-Vargas" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of murder and carrying a pistol without a permit, holding that there was no error or abuse of discretion in the proceedings below.On appeal, Defendant argued that the trial court abused its discretion in excluding evidence of an assault of one of the state's witnesses and that the trial court erred by preventing him from impeaching another witness with evidence of previous criminal offenses. The Supreme Court affirmed, holding (1) the trial court's exclusion of evidence related to the assault did not violate Defendant's constitutional rights to present a defense and to confront the witnesses against him; and (2) the trial court did not violate Defendant's constitutional right to confrontation or the rules of evidence by preventing him from impeaching the witness with evidence of certain prior criminal convictions. View "State v. Torres" on Justia Law

The Supreme Court affirmed the judgment of the appellate court affirming the judgment of the trial court denying Defendant's motion to open the judgment in this marital dissolution case on the basis of fraud, holding that the appellate court properly affirmed the trial court's denial of Defendant's motion to open.Following a trial, the dissolution court issued a decision dissolving the parties' marriage and issuing certain financial orders. Defendant later filed this motion claiming that Plaintiff had committed fraud by denying the existence of a sexual relationship with another man during the course of the marriage and by testifying that Defendant had physically assaulted her. The trial court denied the motion, and the appellate court affirmed. The Supreme Court affirmed, holding that there was no abuse of discretion in the denial of Defendant's motion to open. View "Conroy v. Idlibi" on Justia Law

In this personal injury action, the Supreme Court reversed the judgment of the appellate court reversing the judgment of the trial court granting the joint motion for additurs filed by Plaintiffs and awarding each plaintiff additional money for pain and damages, holding that the trial court did not abuse its discretion by granting Plaintiffs' joint motion for additurs.Plaintiffs, William Maldonado and Geovanni Hernandez, filed a negligence action against Defendants after a car accident. The jury returned a verdict in favor of Plaintiffs and awarded economic damages in the amount of $17,228 to Maldonado and $11,864 to Hernandez but declined to award noneconomic damages. The trial court granted Plaintiffs' motion for additurs, concluding that the jury verdict was inherently inconsistent and awarding past economic damages in the amount of $8000 to Maldonado and $6500 to Hernandez. The Supreme Court reversed, holding (1) the trial court's explanation of the basis for the additur award was sufficient; and (2) the trial court did not abuse its discretion by granting Plaintiffs' joint motion for additurs. View "Maldonado v. Flannery" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the trial court in this case arising from allegations of sexual harassment brought by the complainant, a judicial marshal who was employed by the Connecticut Judicial Branch, holding that remand was required.A human rights referee with the Commission on Human Rights and Opportunities concluded that the the allegations were substantiated and awarded the complainant back pay, emotional distress damages, injunctive relief, and attorney's fees. The trial court reversed in part, concluding that the award of emotional distress damages must be vacated due to the complainant's failure to comply with discovery requests and that the injunction reinstating the complainant to her former workplace must be vacated as overbroad. The Supreme Court affirmed in part and reversed in part, holding that the trial court (1) properly concluded that emotional distress damages and attorney's fees were available remedies; but (2) erred in upholding the referee's determination that the state waived its sovereign immunity with respect to prejudgment and post judgment interest awards for civil rights violations. View "Connecticut Judicial Branch v. Gilbert" on Justia Law

The Supreme Court reversed the judgment of the trial court reversing the decision of the Board of Firearms Permit Examiners ordering the issuance of a pistol permit to Defendant, holding that the Board did not abuse its discretion in finding that Defendant was suitable to obtain a pistol permit in Connecticut.While Conn. Gen. Stat. 29-28(b) prohibits the issuance of a permit to carry a pistol or revolver if the applicant has been convicted of a felony or certain enumerated offenses it contains no language prohibiting the issuance of a permit based on out-of-state, nonfelony convictions. Defendant in this case appealed the judgment of the trial court reading section 29-28(b)(2)(B) to include extraterritorial misdemeanor convictions. The Supreme Court reversed, holding that the trial court improperly substituted its judgment for the Board that Defendant was a suitable person to obtain a pistol permit. View "Stratford Police Department v. Board of Firearms Permit Examiners" on Justia Law

The Supreme Court reversed in part the judgment of the trial court in this action alleging housing discrimination, holding that the court's ultimate conclusion as to liability on the facts of this case was clearly erroneous with respect to Sarah Henry, a licensed real estate salesperson.Plaintiff brought this complaint against several real estate defendants, alleging housing discrimination. The trial court rendered judgment in favor of Defendants, concluding that Plaintiff failed to prove that Defendants had discriminated against her. Plaintiff appealed, arguing that the trial court improperly considered whether Henry had the subjective intent to discriminate when she made certain statements. The Supreme Court reversed in part, holding (1) the trial court applied the proper legal standard in considering Plaintiff's claims under Conn. Gen. Stat. 46a-64c(a)(3); but (2) the trial court's finding that Henry's statements did not convey a discriminatory message to an ordinary listener was clearly erroneous. View "Lopez v. William Raveis Real Estate, Inc." on Justia Law