Justia Connecticut Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of two counts of risk of injury to a child. The appellate court reversed the conviction and remanded the case for a new trial. The State appealed, claiming that the appellate court improperly concluded that (1) the trial court abused its discretion in admitting into evidence four statements by an expert witness, each to the effect that the complainant exhibited behaviors consistent with those of sexual abuse victims; and (2) reversal was required because these improper evidentiary rulings were not harmless error. The Supreme Court affirmed, holding that the four statements were improperly admitted into evidence, and the Court did not have a fair assurance that those improprieties did not substantially sway the jury's verdict. View "State v. Favoccia" on Justia Law

After a jury trial, Defendant was convicted of murder and conspiracy to commit murder. The Supreme Court affirmed, holding (1) there was sufficient evidence to sustain Defendant's conviction of conspiracy to commit murder; (2) the prosecutor did not engage in impropriety by eliciting from a key state witness a statement that she would never lie, and the prosecutor did not argue outside of the evidence in his rebuttal argument, and therefore, the prosecutor did not engage in improper conduct; and (4) the record was ineffective was inadequate for review of both of Defendant's claims of ineffective assistance of counsel, and accordingly, the ineffective assistance claims should be resolved after an evidentiary hearing in the trial court. View "State v. Taft" on Justia Law

After a jury trial, Defendant was convicted of sexual assault in the first degree and kidnapping in the first degree in violation of Conn. Gen. Stat. 53a-92(a)(2)(A). After a trial to the court, Defendant was convicted of violation of probation. Defendant appealed, raising two claims of error. The Supreme Court reversed in part the judgment of the trial court, holding (1) the court erred in omitting limiting language in instructing the jury that the phrase "without consent," as defined by Conn. Gen. Stat. 53a-91(a)(1) includes "any means whatsoever, including acquiescence of the victim," for purposes of the restraint element of section 53a-92(a)(2); and (2) it was reasonably possible that the trial court's improper instruction had the effect of misleading the jury, and a new trial was, therefore, required on the kidnapping charge. View "State v. Devalda" on Justia Law

At issue in this appeal was whether a national fraternity and one of its local Connecticut chapters may be held liable in common-law negligence for the death of one of its members, which occurred while driving back to New Haven after a fraternity event held in New York City. On appeal, Plaintiff, the administrator of the estate of Decedent, claimed the trial court improperly rendered summary judgment for Defendants, Delta Kappa Epsilon National Fraternity and its Delta Kappa Epsilon Phi Chapter. The Supreme Court reversed, holding (1) as a matter of law, Phi Chapter voluntarily assumed a duty of care regarding Decedent's safe transportation, and therefore, Plaintiff sufficiently alleged a claim of common-law negligence; and (2) Plaintiff raised a material question of fact regarding Delta National's control over Phi Chapter. View "Grenier v. Comm'r of Transp." on Justia Law

After a jury trial, Defendant was convicted of, inter alia, sexual assault in the first degree. Defendant appealed, claiming that the trial court improperly denied his motion to dismiss because the statute of limitations applicable to the offense had expired and had not been tolled because he left the state. Defendant's principal assertion was that he did not flee the state because he was returning to his home in Massachusetts after the commission of the crime. The Supreme Court affirmed, holding (1) it was undisputed that Defendant returned to Massachusetts after the commission of a crime and continued to reside there until his arrest more than twenty years later, and accordingly, the trial court properly denied Defendant's motion to dismiss because it properly concluded that the state had shown probable cause that the statute of limitations had been tolled; (2) the trial court properly denied Defendant's motion for a judgment of acquittal because the state proved there was sufficient evidence that Defendant fled the state; and (3) the trial court's instructions on the statute of limitations defense were not misleading. View "State v. Ward" on Justia Law

A jury found Defendant guilty of sexual assault in the first degree and kidnapping in the first degree. The trial court granted Defendant's motion for judgment of acquittal on the kidnapping charge on the ground that the State had failed to prove beyond a reasonable doubt that Defendant intended to prevent the liberation of the victim for a longer period of time or to a greater degree than that which was necessary to commit the sexual assault as required by State v. Salamon. The Supreme Court reversed the judgment of the trial court as to the kidnapping charge, holding (1) the trial court improperly improperly granted Defendant's motion for judgment of acquittal and rendered judgment of not guilty on the kidnapping charge, as the jury reasonably could have concluded that Defendant's restraint of the victim was not merely incidental to the sexual assault; (2) the judgment may not be affirmed on the alternate ground that the kidnapping statute, as applied to Defendant's conduct, was unconstitutionally vague; and (3) the trial court's instruction on the kidnapping charge was not misleading. Remanded. View "State v. Ward" on Justia Law

After a jury trial, Petitioner was convicted of capital felony, two counts of murder, and conspiracy to commit murder, and he was sentenced to an effective term of life imprisonment without the possibility of release. The Supreme Court upheld all four convictions on appeal. Petitioner subsequently filed an amended petition for a writ of habeas corpus, alleging that he had been denied the effective assistance of counsel based on his claim that counsel failed to complete an adequate pretrial investigation. The habeas court granted petitioner's petition, and the appellate court affirmed. The Supreme Court affirmed, holding that Petitioner established by a preponderance of he evidence both that defense counsel had rendered ineffective assistance and that the alleged ineffective assistance was prejudicial to Petitioner. View "Gaines v. Comm'r of Corr." on Justia Law

Plaintiff filed a complaint with the department of labor against her employer (Employer), alleging a violation of the Connecticut family and medical leave statute, which applies only to employers that employer seventy-five or more employees. Although Employer employed more than 1,000 employees nationwide, the commissioner of labor dismissed the complaint on the ground that the leave statute does not apply to Employer because it does not employ seventy-five or more employees within the state of Connecticut. The trial court sustained Plaintiff's appeal and rendered judgment in Plaintiff's favor, concluding that all employees of a business are to be counted in determining whether the business is an employer under the leave statute. The Supreme Court reversed, holding that section Conn. Agencies Regs. 31-51qq-42, which has the force and effect of a statute, makes clear that only Connecticut employees are to be counted under the leave statute. View "Velez v. Comm'r of Labor" on Justia Law

Physician diagnosed and treated Patient for various liver and kidney ailments but failed to warn her of the latent driving impairment associated with her condition. After leaving Physician's office, Patient blacked out while operating her motor vehicle and struck Plaintiff. Plaintiff brought an action against Physician and his employer (collectively, Defendants) for professional negligence. The trial court found in favor of Defendants, finding that Physician owed no duty to Plaintiff to warn Patient of the driving risks associated with her medical conditions. The Supreme Court affirmed, and in so doing, declined to extend a health care provider's duty through judicial modification, holding that the trial court properly found that Physician owed no duty to Plaintiff to advise or warn Patient of the latent driving impairment associated with her medical condition. View "Jarmie v. Troncale" on Justia Law

The named plaintiff, on her own behalf and on behalf of her minor son, brought this action against defendant city (Defendant), claiming that her son incurred injuries when a fellow student pushed him into a broken locker. Defendant filed its its answer and a special defense claiming municipal immunity. Plaintiffs denied the special defense but failed to plead that any exception to the defendant's immunity applied to them. The court instructed the jury on principles of negligence but made no reference to the special defense. The jury rendered a verdict for Plaintiffs. The trial court then granted Defendant's motion for a directed verdict and the motion to set aside the verdict on the ground of governmental immunity and rendered judgment for Defendant. The appellate court affirmed on the alternative ground that Plaintiffs failed to plead the identifiable victim, imminent harm exception to municipal immunity in their reply. The Supreme Court reversed, holding that because Plaintiffs did not have adequate notice of this alternative basis or sufficient opportunity to address it, the appellate court improperly decided the case on the basis of Plaintiffs' failure to plead the imminent harm exception to discretionary act immunity. View "Haynes v. City of Middletown" on Justia Law