Justia Connecticut Supreme Court Opinion Summaries

The decedent in this case maintained residences in Connecticut, Arizona, and Florida, dividing his time among them. After his death, his estate’s executor filed a Connecticut domicile declaration, which triggered an audit by the Department of Revenue Services. The audit division, weighing several factors, determined the decedent was domiciled in Connecticut, making his estate subject to Connecticut estate tax. The commissioner’s appellate division affirmed this determination, and the executor appealed to the Superior Court, arguing the decedent was a Florida domiciliary and raising claims of procedural due process violations during the audit process.Upon de novo review, the Superior Court heard testimony and admitted numerous exhibits regarding the decedent’s personal, social, and property ties to Connecticut and Florida. The court found these connections to be generally equal but concluded that the executor failed to show by clear and convincing evidence that the decedent was not a Connecticut domiciliary. Thus, it upheld the tax assessment. The court also rejected the executor’s claim of procedural due process violations, holding that any such errors were cured by subsequent review and the de novo trial.The Connecticut Supreme Court reviewed the case and held that, under General Statutes § 12-391 (h) (1), the proper standard for an estate challenging a domicile determination in an estate tax appeal is the preponderance of the evidence, not clear and convincing evidence. The court concluded that the Superior Court erred by applying the higher standard, reversed the judgment upholding the commissioner’s assessment, and remanded for a new trial limited to the issue of domicile under the correct standard. The Supreme Court affirmed the trial court’s rejection of the procedural due process claim, finding that the de novo review cured any procedural deficiencies. View "Daniels v. Commissioner of Revenue Services" on Justia Law

The plaintiff landlord leased an apartment to the defendant tenant, offering a discounted rent with the understanding that the rent would increase after the first year. As the renewal approached, the landlord sought to raise the rent to the higher amount. The tenant filed a complaint with the Hartford Fair Rent Commission, alleging the increase was excessive. While the commission’s review was pending, the landlord attempted to collect the increased rent and, when the tenant continued paying the lower amount, initiated eviction proceedings for nonpayment. The commission ultimately ruled in the tenant’s favor, finding the increase unfair and that the eviction attempt was retaliatory. The commission ordered the landlord to maintain the lower rent and to cease and desist from the eviction.After the commission’s decision, the landlord began a summary process (eviction) action in the Superior Court and also filed an administrative appeal challenging the commission’s ruling. In the summary process action, the tenant raised defenses of retaliation and sought dismissal based on the commission’s order. The trial court, Housing Session of the Superior Court in Hartford, granted the tenant’s motion to stay the eviction action pending resolution of the administrative appeal. The landlord’s motion to reconsider was denied, prompting an interlocutory appeal to the Connecticut Supreme Court, certified as a matter of substantial public interest.The Connecticut Supreme Court held that the trial court had inherent authority to stay the summary process action, despite the expedited nature of such proceedings, because the commission’s findings about the proper rent and retaliation could directly affect the merits of the eviction case. The court concluded that the trial judge properly balanced the interests of both parties, the commission, and judicial efficiency, and did not abuse its discretion in granting the stay. The Supreme Court affirmed the stay order and declined to address the landlord’s constitutional challenges and other issues not yet decided by the trial court. View "TOV Realty, LLC v. Suarez" on Justia Law

The case centers on a foreclosure action brought by a bank that sought to enforce a mortgage on property owned by the defendant. The defendant had executed a promissory note secured by a mortgage with a predecessor lender. After the defendant defaulted, Bank of America became the holder of the note and owner of the debt, and the mortgage was later assigned to the plaintiff bank. However, during the period Bank of America held the note, the original note was lost while in the custody of its loan servicer. The plaintiff bank, as the assignee, initiated foreclosure proceedings and moved for summary judgment, presenting affidavits from employees of the loan servicer as secondary evidence of its ownership of the debt.The Superior Court, Judicial District of Danbury, granted summary judgment as to liability in favor of the plaintiff and subsequently rendered a judgment of strict foreclosure. The defendant appealed, arguing that the affidavits submitted were insufficient to prove the plaintiff’s ownership of the debt. The Appellate Court affirmed the trial court’s decision, prompting a further appeal to the Supreme Court of Connecticut.The Supreme Court of Connecticut reversed the Appellate Court’s judgment. It held that the plaintiff failed to show there was no genuine issue of material fact regarding its ownership of the debt, as required for summary judgment. The court found the affidavits submitted by the plaintiff were either inadmissible due to lack of personal knowledge or were conclusory and lacked a sufficient factual foundation. The court explained that, when a note is lost, secondary evidence must clearly and competently establish ownership of the debt, which was not done in this instance. The case was remanded for further proceedings. View "Wilmington Savings Fund Society, FSB v. Schulz" on Justia Law

The case centers on the fatal shooting of a man outside his Hartford residence. An eyewitness, Shamar Coachman-Brown, who was personally familiar with the defendant due to past family connections, was present before, during, and after the shooting. Coachman-Brown initially hesitated to identify the defendant in a police photo array, only later doing so after repeated questioning and pressure from detectives. The defendant was subsequently charged with murder and criminal possession of a firearm.At the Superior Court for the judicial district of Hartford, the defendant moved to suppress Coachman-Brown’s out-of-court identification, arguing that the identification procedure was unnecessarily suggestive and likely to lead to misidentification. The trial court agreed, suppressing the out-of-court identification but later granted the State’s motion to allow Coachman-Brown to identify the defendant in court, finding his identification to have an independent basis. The murder charge was tried to a jury which found the defendant guilty, while the firearm charge was tried to the court, which also found the defendant guilty. The defendant was sentenced to forty-five years and appealed.The Connecticut Supreme Court reviewed whether the admission of the in-court identification violated the defendant’s federal and state due process rights, given the prior suppression of the out-of-court identification. The court held that Coachman-Brown’s in-court identification was based on an independent source, supported by his prior familiarity with the defendant, ample opportunity to observe him during the crime, and his expressed certainty. The court declined to adopt a new rule that would have presumptively barred such identifications, reaffirming the independent source doctrine. The judgment of conviction was affirmed. View "State v. Rohena" on Justia Law

After the death of her husband, the plaintiff became the sole owner of certain residential property previously held in joint tenancy. The plaintiff, serving as executor of her late husband’s estate, leased the property to one of the defendants, her son, under an agreement that expired in 2020. The defendants, who are immediate family members, continued to occupy the property after the lease expired. In August 2021, the plaintiff, represented by counsel, served a notice to quit on the defendants, which identified her as “executor,” and then initiated a summary process action using that same designation.The case was brought in the Superior Court, Housing Session at Stamford-Norwalk, where the plaintiff moved to substitute herself in her individual capacity, as the owner, rather than as executor. The court granted the substitution without objection from the defendants. After a bench trial, the court found in favor of the plaintiff and issued a judgment of possession, rejecting the defendants’ claims of a life estate and other defenses. The defendants appealed to the Connecticut Appellate Court, arguing for the first time that the notice to quit was jurisdictionally defective because it was issued by the plaintiff as “executor,” although the estate never owned the property. The Appellate Court affirmed, finding the notice to quit sufficient under Connecticut General Statutes § 47a-23(a).Upon further appeal, the Connecticut Supreme Court disagreed that the notice to quit strictly complied with § 47a-23(a) due to the incorrect reference to the plaintiff as “executor.” However, the Court held that this was a circumstantial, not substantive, defect under General Statutes § 52-123. Since the notice conveyed all essential information and there was no prejudice or confusion to the defendants, the trial court retained subject matter jurisdiction. The Supreme Court affirmed the judgment of the Appellate Court. View "Freccia v. Freccia" on Justia Law

Several electric suppliers, previously licensed to operate in Connecticut, entered into a settlement agreement with the Public Utilities Regulatory Authority (PURA) in 2022. This agreement resolved an investigation into the suppliers’ regulatory compliance. Under the agreement, the suppliers agreed to withdraw from the state market, make certain payments, and provide documentation demonstrating their compliance with the state’s renewable portfolio standards (RPS) for 2022. PURA approved the agreement, and the suppliers submitted the required documentation, after which PURA confirmed their compliance and returned their security deposits.Subsequently, PURA initiated its annual uncontested proceeding to review all suppliers’ compliance with the 2022 RPS, as mandated by statute. The plaintiffs resubmitted their compliance documents. However, PURA determined the suppliers had not fully satisfied their RPS obligations due to discrepancies in load data calculations and ordered additional payments exceeding $1 million. The suppliers then sought a declaratory ruling from PURA, arguing they had fulfilled their obligations under the settlement, but PURA declined, citing the ongoing RPS proceeding. After PURA issued its final decision in the uncontested proceeding, the suppliers filed suit in the Superior Court, seeking both an administrative appeal and a declaratory judgment. The Superior Court dismissed both claims: the administrative appeal for lack of a final agency decision, and the declaratory judgment for failure to exhaust administrative remedies.The Connecticut Supreme Court affirmed the dismissal of the administrative appeal, finding that PURA’s decision in an uncontested proceeding was not a “final decision” subject to judicial review under the Uniform Administrative Procedure Act. However, the Supreme Court reversed the dismissal of the declaratory judgment claim. It held that the suppliers had exhausted their administrative remedies by seeking a declaratory ruling and participating in the RPS proceeding, and that the trial court had jurisdiction to consider their request for a declaratory judgment regarding the applicability of the relevant statutes to their circumstances. The case was remanded for further proceedings on the declaratory judgment claim. View "Vistra Corp. v. Public Utilities Regulatory Authority" on Justia Law

The parties in this case are former spouses who share a minor daughter. Their marriage was dissolved in 2019, and they were awarded joint legal and physical custody. Following the dissolution, both filed numerous motions related to custody, resulting in increased litigation. In 2022 and 2023, each sought sole custody through postjudgment modification motions. The trial court held an evidentiary hearing over several dates to resolve these motions and others. Ultimately, the court awarded the defendant sole legal and primary physical custody, issuing its decision 133 days after the close of evidence.After the decision, the plaintiff moved to void and set aside the custody order, arguing that the decision was untimely under General Statutes § 51-183b, which sets a 120-day deadline for rendering judgment. The Superior Court, Judicial District of Hartford, denied this motion, ruling that postjudgment modification motions are “short calendar matters” governed by Practice Book § 11-19, not § 51-183b. Under § 11-19, the party must file a motion for reassignment within 14 days after the 120-day deadline to preserve a timeliness objection, which the plaintiff did not do. The trial court also did not expressly rule on two contempt motions, and, without prior notice to the parties, it took judicial notice of the plaintiff’s conduct in a prior, unrelated custody proceeding involving a different child.The Connecticut Supreme Court held that the plaintiff had waived her timeliness objection by failing to follow the procedure set forth in Practice Book § 11-19. The court declined to review the claim regarding the unresolved contempt motions, as the plaintiff had not requested a ruling or sought articulation. However, the Supreme Court found that the trial court abused its discretion by sua sponte taking judicial notice of facts from the unrelated custody proceeding without giving the plaintiff notice and an opportunity to respond. This error was harmful because it significantly influenced the custody decision. The Supreme Court reversed the custody award and remanded for further proceedings, affirming the decision in all other respects. View "Hamilton v. Hamilton" on Justia Law

The case involved a fatal shooting following a fight between two rival groups in Hartford in 2008. The defendant was associated with one group, while the victim was affiliated with the other. During a concert, a conflict erupted and continued outside the venue, where the defendant and his associates armed themselves. The victim, after the confrontation, was shot multiple times by the defendant and later died from his wounds. The case, initially unsolved, was revived years later based on sworn statements from several eyewitnesses and acquaintances, some of whom identified the defendant as the shooter or recounted his admissions.After the defendant was charged with murder, the case proceeded to trial before the Connecticut Superior Court, Judicial District of Hartford. During the trial, an incident arose involving Juror 7, who reportedly expressed safety concerns after interactions with trial attendees. The trial court excused Juror 7 following a canvass but, after a thorough individual canvass of the remaining jurors, denied the defense's motion for a mistrial and refused to excuse three other jurors who were alleged to have overheard or been affected by Juror 7’s concerns. The jury found the defendant guilty, and he was sentenced to forty years in prison.On direct appeal to the Connecticut Supreme Court, the defendant argued that the trial court erred by not declaring a mistrial or excusing additional jurors, and also claimed prosecutorial impropriety during witness examination. The Connecticut Supreme Court held that the trial court did not abuse its discretion in denying the mistrial motion or in excusing only Juror 7, finding no evidence of prejudicial juror tampering or bias. The court further held there was no prosecutorial impropriety that deprived the defendant of a fair trial. The judgment of conviction was affirmed. View "State v. Brown" on Justia Law

An electric utility company sought to recover capital costs it incurred repairing damage from five catastrophic storms that hit Connecticut after it had entered into a settlement agreement with the state’s utility regulator. The settlement agreement, approved in 2018, established new base rates for the company from 2018 through 2020 and created a mechanism—called the new capital tracker—allowing the company to recover certain infrastructure investments. During negotiations, the parties amended the agreement to address storm-related costs, allowing the utility to seek recovery of these costs either in a future rate case or a separate proceeding. The utility initiated a contested case to recover storm operation and maintenance costs but did not seek review or approval of related capital costs at that time, instead seeking to recover those capital costs during an annual rate adjustment in 2021.The Public Utilities Regulatory Authority (PURA), in its decision on the 2021 rate adjustment, denied the company’s attempt to recover over $17 million in capital costs related to storm repairs in its current base rates, reasoning that the settlement agreement did not unambiguously provide for such recovery and that approval of those costs should occur in a future rate case. The utility appealed. The Superior Court upheld PURA’s decision, deferring to PURA’s rate-making discretion and finding substantial evidence to support its action, without interpreting the disputed sections of the settlement agreement.The Supreme Court of Connecticut reviewed the matter and held that the trial court erred by not first interpreting the settlement agreement to determine whether it was clear and unambiguous before deferring to PURA’s discretion. The Supreme Court found the agreement to be ambiguous regarding recovery of storm-related capital costs and concluded that neither the administrative record nor extrinsic evidence resolved this ambiguity. The case was remanded for further proceedings to resolve the contractual ambiguities. View "Connecticut Light & Power Co. v. Public Utilities Regulatory Authority" on Justia Law

The case concerns a fatal shooting that occurred after the victim arranged to meet the defendant at a public park. The victim, accompanied by four others, approached the defendant and his companion. According to eyewitness accounts, the victim was unarmed, exchanged brief words with the defendant, and then the defendant drew a gun and pointed it at the victim. The victim told his group to run and attempted to flee himself, at which point the defendant fired multiple shots, striking and killing the victim as he ran away.Following the incident, the defendant was charged with murder in the Superior Court for the judicial district of Hartford. At trial, he did not testify but sought to assert self-defense through cross-examination of the state’s witnesses. The trial court instructed the jury on self-defense, the duty to retreat, and several lesser included offenses. The jury rejected the self-defense claim and convicted the defendant of murder. The defendant was sentenced to forty-eight years in prison and appealed his conviction directly to the Supreme Court of Connecticut.On review, the Supreme Court of Connecticut held that the evidence was sufficient for the jury to reject the claim of self-defense beyond a reasonable doubt. The Court found that eyewitness testimony and physical evidence supported the conclusion that the victim was not armed, did not attack, and was attempting to escape when shot. The Court also determined that the state had proven the defendant could have safely retreated. Furthermore, the Court found no plain error in the trial court’s jury instructions on intent, proximate cause, or general intent, concluding that the instructions, when read as a whole, did not mislead the jury or dilute the state’s burden of proof. The conviction was affirmed. View "State v. Baez" on Justia Law