Justia Connecticut Supreme Court Opinion Summaries

A woman was injured when a heat lamp manufactured by a company made contact with her foot during an acupuncture session performed by a physician. She initially sued the physician and his employer for medical malpractice. The physician then filed a third-party complaint against the manufacturer, alleging product liability. The injured woman subsequently filed a direct product liability claim against the manufacturer. The manufacturer raised special defenses, asserting that both the woman and the physician bore comparative responsibility for her injuries and that, if found liable, it would be entitled to contribution from the physician. Before trial concluded, the physician withdrew his third-party complaint. The jury found the manufacturer 80 percent responsible and the physician 20 percent responsible for the woman’s damages.After judgment was rendered, the Connecticut Appellate Court reversed the judgment as to the medical malpractice claim against the physician for lack of personal jurisdiction but affirmed the product liability judgment, including the jury’s allocation of comparative responsibility. The Connecticut Supreme Court denied the manufacturer’s petition for certification to appeal, and the woman withdrew her appeals after receiving payment in satisfaction of the judgment.The manufacturer and its insurer then filed a contribution action against the physician, seeking to recover 20 percent of the amount paid to the injured woman. The Superior Court granted summary judgment in favor of the manufacturer and its insurer. On appeal, the physician argued that he was not a party subject to the comparative responsibility provisions of the Connecticut Product Liability Act and that the contribution action was untimely.The Connecticut Supreme Court held that all defendants in an action involving a product liability claim, regardless of whether they are product sellers, are subject to comparative responsibility under the statute. The Court also held that a contribution action is timely if brought within one year after all appellate proceedings in the underlying action are final. The judgment in favor of the manufacturer and its insurer was affirmed. View "Health Body World Supply, Inc. v. Wang" on Justia Law

A four-year-old child drowned after wandering unattended from the home where she had been placed under temporary custody by order of the Probate Court. The child’s parents had previously lost guardianship, and the court had vested temporary custody in maternal relatives. To determine whether to grant a full transfer of guardianship, the Probate Court ordered the Department of Children and Families (DCF) to investigate the home and report its findings. DCF submitted its report, recommending the placement, but before the court could hold a hearing on permanent guardianship, the child died. The child’s estate, through her father as administrator, alleged that DCF’s negligence in investigating the placement and in making recommendations to the Probate Court was a proximate cause of the child’s death, and also claimed DCF failed to fulfill independent duties to protect the child from abuse and neglect.After the estate received permission from the Claims Commissioner to sue the state, DCF moved to dismiss the action in the Superior Court, arguing that it was entitled to absolute quasi-judicial immunity for actions integral to the judicial process, such as conducting court-ordered investigations and making recommendations. The Superior Court agreed, holding that DCF was protected by absolute quasi-judicial immunity when acting as an arm of the Probate Court, and that the Claims Commissioner could not waive this immunity. The court dismissed the action, finding the complaint’s allegations insufficient to overcome DCF’s immunity.On appeal, the Connecticut Supreme Court held that the Claims Commissioner’s waiver of sovereign immunity under the relevant statute does not preclude the state from asserting absolute quasi-judicial immunity. However, the Court reversed in part, concluding that some of the estate’s allegations may fall outside the scope of quasi-judicial immunity, particularly those involving DCF’s independent statutory duties. The case was remanded for further proceedings to determine which claims, if any, are not barred by quasi-judicial immunity. View "Jamie G. v. Dept. of Children & Families" on Justia Law

The defendant was previously convicted of murder and criminal possession of a firearm. This court reversed the murder conviction due to the prosecutor's improper comments on the defendant's post-Miranda silence, violating Doyle v. Ohio. The defendant then moved to dismiss the murder charge, arguing that double jeopardy protections barred a retrial because the prosecutor intended to prevent an acquittal that was imminent without the impropriety.The trial court denied the motion to dismiss, finding that the defendant did not establish that the prosecutor intended to prevent an acquittal. The court based its decision on the trial transcripts and this court's previous decision, which concluded that the evidence was sufficient to support the conviction. The defendant appealed, renewing his argument that the double jeopardy clause barred a retrial and asserting that the Connecticut constitution provided broader protections.The Supreme Court of Connecticut affirmed the trial court's decision. The court held that the defendant failed to demonstrate that the prosecutor engaged in impropriety with the intent to prevent an acquittal that the prosecutor believed was imminent. The court noted that the evidence at trial, although not overwhelming, was sufficient to support a conviction, and the prosecutor's actions did not indicate an intent to provoke a mistrial or prevent an acquittal. The court also declined to overrule its previous decisions in State v. Colton and State v. Michael J., maintaining that the Connecticut constitution does not provide broader double jeopardy protections than the federal constitution. View "State v. Patrick M." on Justia Law

In 2017, the Commissioner of Children and Families obtained an order of temporary custody for a minor child, Andrew, and placed him with foster parents. Years later, the foster parents filed a motion to intervene in response to the biological father's motion to revoke Andrew's commitment, which was granted in 2020. In 2021, the court denied the father's motion to revoke commitment, granted the foster parents' motion to transfer guardianship of Andrew to them, and rendered judgment accordingly.In 2023, the Appellate Court decided In re Ryan C., holding that nonrelative foster parents are prohibited by statute from intervening in neglect proceedings. Following this decision, the biological father filed a motion to open and vacate the 2021 judgment transferring guardianship of Andrew to the foster parents, arguing that the court lacked subject matter jurisdiction to entertain the foster parents' motion to transfer guardianship. The trial court agreed, vacating the order granting the foster parents' motion to intervene and the judgment transferring guardianship.The Supreme Court of Connecticut reviewed the case and reversed the Appellate Court's judgment. The Supreme Court held that the Appellate Court improperly upheld the trial court’s decision to grant the father's motion to open and vacate the 2021 judgment. The Supreme Court determined that the trial court had jurisdiction to grant the foster parents' motion to intervene and their motion to transfer guardianship in 2021. Consequently, the trial court lacked authority to open the 2021 judgment more than four months after notice of that judgment was sent. The Supreme Court directed the Appellate Court to reverse the trial court’s decision and to reinstate the earlier order granting the foster parents’ motion to intervene and the 2021 judgment transferring guardianship of Andrew to the foster parents. View "In re Andrew C." on Justia Law

The plaintiff sought to foreclose two municipal tax liens for the grand lists of 2012 and 2013 on real property owned by the defendant. The city of Bridgeport had purportedly assigned the tax liens to the plaintiff’s predecessor, which then allegedly assigned its interest to the plaintiff. The defendant filed an answer and several special defenses, including a claim that the Bridgeport City Council had not validly assigned the liens. The trial court granted the plaintiff’s motion for summary judgment as to liability, concluding there was no genuine issue of material fact regarding the validity of the assignments. Subsequently, the trial court rendered a judgment of foreclosure by sale.The defendant appealed to the Appellate Court, which affirmed the trial court’s judgment. The defendant then appealed to the Connecticut Supreme Court, arguing that the plaintiff did not provide sufficient proof that the city council had made a resolution to assign the tax liens to the plaintiff.The Connecticut Supreme Court affirmed the Appellate Court’s decision, holding that the plaintiff had met its burden of establishing the validity of the assignments. The court found that the plaintiff submitted certified copies of the city council’s meeting agendas and minutes, which showed that the council had authorized the assignments. The court also noted that the defendant failed to present any evidence to create a genuine issue of material fact regarding the validity of the assignments. The court clarified that the plaintiff bore the burden of proving standing and had satisfied this burden, while the defendant’s mere assertions were insufficient to defeat summary judgment. The court also addressed procedural irregularities but concluded that the defendant had waived any related claims by not objecting. View "Cazenovia Creek Funding I, LLC v. White Eagle Society of Brotherly Help, Inc." on Justia Law

The plaintiff sought damages from the Department of Children and Families (DCF), alleging religious discrimination during child protection proceedings that led to the termination of his parental rights. The trial court dismissed most of the plaintiff’s claims as time-barred but allowed some timely allegations related to the termination trial to proceed. DCF’s motion to reargue, asserting that the litigation privilege barred the remaining claims, was denied by the trial court.DCF appealed to the Appellate Court, which concluded that the litigation privilege did indeed bar the plaintiff’s remaining timely allegations and directed the trial court to dismiss the complaint in its entirety. The trial court complied, dismissing the entire complaint before the plaintiff could seek further appellate review.The plaintiff and the Commission on Human Rights and Opportunities argued that the Appellate Court erred in applying the litigation privilege to bar the discrimination claims. They contended that the privilege should not apply to DCF, a governmental entity, and that the legislature intended to abrogate the privilege in discrimination cases.The Connecticut Supreme Court held that the litigation privilege barred the plaintiff’s timely allegations related to DCF’s conduct during the termination trial. The court reasoned that the plaintiff’s claims were akin to defamation, to which the privilege applies, and not to vexatious litigation, which challenges the purpose of the underlying action. The court also found that other remedies were available to address DCF’s conduct and declined to adopt a rule precluding nonpersons from invoking the privilege.However, the Supreme Court reversed the Appellate Court’s judgment to the extent that it directed the trial court to dismiss the entire complaint, as this hindered the plaintiff’s ability to appeal the dismissal of his untimely claims. The case was remanded to the Appellate Court to vacate the trial court’s judgment and to remand the case for a new judgment of dismissal, allowing the plaintiff to appeal the timeliness ruling. View "Ammar I. v. Dept. of Children & Families" on Justia Law

The case involves the foster parents of a minor child, J, who were initially granted intervenor status in neglect proceedings concerning J. The trial court later removed them as intervenors based on the Appellate Court's decision in In re Ryan C., which concluded that nonrelative foster parents are precluded by statute from intervening in neglect proceedings. The foster parents appealed this decision, arguing that In re Ryan C. was wrongly decided. While their appeal was pending, the trial court held a hearing on a motion to revoke J's commitment to the Commissioner's custody and transferred guardianship to J's biological father. The foster parents also filed a writ of error challenging this decision.The trial court initially granted the foster parents' motion to intervene in the neglect proceedings. However, after the Appellate Court's decision in In re Ryan C., the trial court removed them as intervenors. The foster parents appealed this removal, claiming that the decision in In re Ryan C. was incorrect. Subsequently, the trial court held a hearing on the motion to revoke J's commitment and transferred guardianship to J's biological father. The foster parents were not allowed to attend the entire hearing or give a sworn statement after hearing the evidence, which they claimed violated their right to be heard under the statute.The Supreme Court of Connecticut reviewed the case and concluded that In re Ryan C. was wrongly decided and must be overruled. The court held that the statute does not bar a trial court from granting a foster parent's request for permissive intervention in the dispositional phase of a neglect proceeding. The court reversed the trial court's order removing the foster parents as intervenors and granted the writ of error, remanding the case for a new revocation hearing. The court also concluded that the foster parents' right to be heard includes the right to be present throughout the proceeding and to argue at the appropriate time as to the child's best interest in light of the evidence presented. View "In re Jewelyette M." on Justia Law

The plaintiffs, property owners in Danbury, Connecticut, challenged the tax assessments on their properties, each valued at over one million dollars, by appealing to the Superior Court. They were required by statute to file appraisals of their properties within 120 days of filing their appeals. The plaintiffs requested extensions to this deadline, which the court granted. However, they failed to file the appraisals with the court by the extended deadlines, although they did provide the appraisals to the defendant's counsel.The trial court initially dismissed five of the six tax appeals for failure to meet the filing deadline, concluding it lacked subject matter jurisdiction. The court later granted the plaintiffs' motions to open the judgments of dismissal and for reargument, citing similar cases where the court had not dismissed appeals under similar circumstances. The court denied the defendant's corrected motion to dismiss the sixth appeal, finding no prejudice to the defendant from the late filing.The defendant appealed to the Connecticut Supreme Court, arguing that the trial court lacked subject matter jurisdiction due to the plaintiffs' failure to timely file the appraisals. The plaintiffs contended that the appeal was moot because they had filed new tax appeals under a recent statutory amendment allowing for such actions if previous appeals were dismissed under certain conditions.The Connecticut Supreme Court held that the appeal was not moot, as the underlying appeals were not "dismissed" for purposes of the new statutory provision, given that the judgments of dismissal had been opened. The court further held that the appraisal filing requirement in § 12-117a (a) (2) is not subject matter jurisdictional. The requirement is mandatory but arises after the commencement of a tax appeal, and the time period for filing the appraisal can be extended by the court for good cause. The judgments of the Superior Court were affirmed. View "7 Germantown Road, LLC v. Danbury" on Justia Law

The plaintiff filed a defamation lawsuit against the defendant after she called him a "white supremacist" on a social media page. The defendant made this statement during a heated political discussion on a town's Facebook page, which was in response to a joint statement by local officials regarding the killing of George Floyd. The plaintiff argued that the term "white supremacist" constituted defamation per se.The trial court, the Superior Court in the judicial district of Waterbury, granted the defendant's special motion to dismiss under Connecticut's anti-SLAPP statute (§ 52-196a). The court determined that the defendant's statements were nonactionable opinions rather than actionable defamation per se. The court also awarded the defendant attorney’s fees and costs. The plaintiff appealed, arguing that the trial court incorrectly concluded that he had failed to show probable cause that he would prevail on the merits of his defamation claim and that the court abused its discretion in awarding attorney’s fees.The Supreme Court of Connecticut reviewed the case and affirmed the trial court's decision. The court held that the term "white supremacist," without more, is a nonactionable opinion rather than actionable defamation per se. The court reasoned that the term lacks a precise meaning, cannot be objectively verified, and does not necessarily imply that the declarant knew existing, undisclosed defamatory facts. The context in which the defendant made the statement—a heated political debate on social media—further supported the conclusion that the statement was an opinion. The court also found no abuse of discretion in the trial court's award of attorney’s fees and costs to the defendant. View "Murphy v. Rosen" on Justia Law

The plaintiff, Larissa Marland, individually and as administratrix of the estate of Norman Marland, filed a medical malpractice claim against the University of Connecticut Health Center and related entities. The decedent had been treated at the hospital and was later admitted to the intensive care unit, where he fell and subsequently died. The plaintiff alleged that the hospital staff breached the standard of care owed to the decedent.The plaintiff filed a notice of claim with the claims commissioner, including a physician’s opinion letter. The claims commissioner failed to resolve the claim within the statutory two-year period and an additional one-year extension granted by the General Assembly. Despite this, the commissioner eventually authorized the plaintiff to sue the state. The plaintiff then filed the present action in the Superior Court.The state moved to dismiss the complaint, arguing that the claims commissioner’s waiver of sovereign immunity was invalid because it was issued after the expiration of the one-year extension. The trial court agreed and dismissed the case for lack of subject matter jurisdiction, concluding that the commissioner did not have the authority to grant the waiver beyond the extension period.The Supreme Court of Connecticut reviewed the case and concluded that the trial court improperly dismissed the plaintiff’s action. The court held that, once the claims commissioner authorizes suit and waives sovereign immunity, the state cannot challenge that decision in the Superior Court. The court emphasized that such challenges should be raised before the claims commissioner. The court reversed the trial court’s judgment and remanded the case with direction to deny the state’s motion to dismiss. View "Marland v. University of Connecticut Health Center" on Justia Law