Justia Connecticut Supreme Court Opinion Summaries

A union initiated arbitration proceedings after a police officer with the town of Stratford was terminated for lying in connection with his employment. A three-member arbitration panel determined that the officer’s termination was excessive and ordered that the town reinstate the officer. The town filed an application to vacate the arbitration award, arguing that the award encouraged police officer dishonesty and thereby violated public policy against lying by law enforcement personnel. The trial court denied the application. The Appellate Court reversed, concluding that the arbitration award violated a clear public policy against intentional dishonesty by police officers in connection with their employment. The Supreme Court reversed, holding (1) there is a public policy against intentional police officer dishonesty in connection with his or her employment, but (2) in this case, the arbitration award reinstating the officer’s employment did not violate that public policy. Remanded. View "Stratford v. AFSCME, Council 15, Local 407" on Justia Law

The parties in this case - a board of education and an education association - proceeded to arbitration on a dispute. The parties proceeded on a three member arbitration panel. When a journalist with a newspaper sought to cover the arbitration proceedings, the panel adjourned to what it designated an executive session, closed to the public. The journalist and newspaper (together, Defendants) filed a complaint with the Freedom of Information Commission, claiming that the panel violated the open meetings provision of the Freedom of Information Act (FOIA). The Commission ordered the members of the arbitration panel and the Department to create a transcript of the hearing and provide that transcript to Defendants, concluding that the arbitration panel was a committee of the Department of Education and that the evidentiary portion of the arbitration proceeding under the Teacher Negotiation Act (TNA) was subject to the open meetings provision of the FOIA. The Supreme Court reversed, holding that because a TNA arbitration panel is not a “committee of” the Department, it does not constitute a “public agency.” View "Gould v. Freedom of Info. Comm’n" on Justia Law

This case concerned a dispute between an insurance carrier (Plaintiff) and its insured (Defendant) regarding Plaintiff’s obligation to pay underinsured motorist benefits. An arbitration panel concluded that the issue of whether the relevant policy provisions provided coverage for the claim should be resolved under the choice of law rules governing claims sounding in tort, rather than claims sounding in insurance and contract, and therefore, that New Jersey law rather than Connecticut law governed Defendant’s claim for uninsured motorist benefits under the policy. The trial court vacated the arbitration award, and the Appellate Court affirmed. The Supreme Court affirmed, holding that the Appellate Court, in its opinion adopting the decision of the trial court, properly applied sections 6(2), 188 and 193 of the Restatement (Second), contract choice of law, to determine that Connecticut law governed the claim. View "Gen. Accident Ins. Co. v. Mortara" on Justia Law

Plaintiff leased property from Defendants pursuant to a lease agreement that included an arbitration clause. Plaintiffs later sued Defendants over disputes regarding the lease. After engaging in litigation with Plaintiff for more than two years, Defendants filed a motion to stay the proceedings pending arbitration under the parties’ lease agreement. Plaintiff objected to the motion, arguing that Defendants had waived their right to enforce the arbitration clause by engaging in lengthy litigation. The trial court granted Defendants’ motion, concluding, as a matter of law, that a party cannot waive enforcement of an arbitration clause in a contract. The Appellate Court affirmed, concluding that the record was inadequate for review because the trial court failed to make any factual findings on the issue of waiver. The Supreme Court reversed, holding (1) because the legal basis of the trial court’s decision was at issue, a factual record on the question of waiver was not necessary to review the trial court’s decision; and (2) the trial court based its judgment on an incorrect statement of the law, and therefore, the court erred in granting Defendants’ motion for a stay pending arbitration. View "MSO, LLC v. DeSimone" on Justia Law

The Town of Malborough terminated the employment of Emily Chaponis as town assessor after the board of selectmen did not make a motion to reappoint her to a successive term of office. Chaponis filed a grievance through the Union, of which she was a member, alleging that the Town violated its collective bargaining agreement with the Union by discharging her without just cause. An arbitration panel ordered the Town to reinstate Chaponis to her position, concluding that the Town violated the agreement when it terminated Chaponis' employment without just cause. The trial court denied the Town's application to vacate the arbitration award. The Supreme Court reversed, holding that the arbitrators' award ordering the reinstatement of Chaponis' employment after the statutory expiration of her term of office contravened the mandates of the statutory scheme governing the term of office for municipal officers, and therefore, the award was unenforceable. Remanded. View "Town of Marlborough v. AFSCME, Council 4, Local 818-052" on Justia Law

After the Town of Westbrook's board of selectmen unanimously voted not to reappoint Ivan Kuvalanka to a successive term of office as town assessor, Kuvalanka filed a grievance asserting that the Town had violated its collective bargaining agreement with the Union, of which Kuvalanka was a member. The arbitrators determined that the grievance was not arbitrable under the agreement. The Union filed an application in the trial court to vacate the award. The trial court denied the application. The Supreme Court affirmed, holding that the trial court (1) properly limited the scope of its review when considering the Union's application to vacate the award; and (2) properly determined that the Union did not establish grounds to vacate the award. View "AFSCME, Council 4. Local 1303-325 v. Town of Westbrook" on Justia Law

Employee was discharged from his employment for allegedly engaging in sexual harassment. Employee's union filed a grievance against Employer, and the parties submitted the controversy to arbitration. The arbitrator reduced the dismissal to a one year suspension without pay, finding the dismissal was without just cause. Employer filed an application to vacate the arbitral award, claiming that enforcement of the award violated public policy. The trial court granted the application and vacated the arbitrator's award on public policy grounds. The appellate court affirmed, holding that the award violated the public policy against workplace sexual harassment. The Supreme Court affirmed, holding that the public policy against sexual harassment in the workplace required nothing less than Employee's termination. View "State v. AFSCME, Council 4, Local 391" on Justia Law

At issue in this certified appeal was whether Plaintiff, the city of New Britain, agreed to arbitrate a dispute with certain city employees, classified as foremen, regarding an alleged violation of the city's civil service rules. The trial court denied Plaintiff's application to vacate the arbitration award in favor of Defendant, AFSCME, Council 4, Local 1186. The appellate court affirmed. The Supreme Court reversed, holding that the appellate court improperly concluded that Plaintiff agreed to arbitrate the foremen's dispute in a settlement agreement between the parties. Because Plaintiff did not agree to arbitrate the dispute, it could not be compelled to submit to arbitration. Remanded with direction to grant Plaintiff's application to vacate the arbitration award. View "City of New Britain v. AFSCME, Council 4, Local 1186" on Justia Law

Plaintiffs, John and Colm Farrell, were allegedly involved in a motor vehicle accident with an insured of Defendant, Twenty-First Century Insurance Company. Plaintiffs filed an action against Defendant, seeking damages for personal injuries arising out of the accident. During a pretrial conference, the parties agreed to settle Plaintiffs' claims and, allegedly, further agreed to arbitrate Plaintiffs' claims. Subsequently, Plaintiffs filed an action against Defendant seeking a court order to compel arbitration. The trial court rendered summary judgment in favor of Defendant, concluding that there was no clear manifestation of an agreement to arbitrate. The appellate court affirmed. The Supreme Court affirmed the judgment of the appellate court, holding that, after drawing all inferences in favor of Plaintiffs, no genuine issue of material fact existed with regard to whether the parties had an enforceable agreement to arbitrate. View "Farrell v. Twenty-First Century Ins. Co." on Justia Law