Justia Connecticut Supreme Court Opinion Summaries

Plaintiffs, Jonathan Keller and a group of business entities, filed a vexatious litigation claim against Defendant, executrix of the estate of Robert Beckenstein. The trial court concluded it lacked jurisdiction over Plaintiffs' complaint because the claim had yet to ripen into a cognizable claim. The appellate court affirmed. The Supreme Court reversed, holding that the appellate court improperly determined that the trial court correctly had concluded that it lacked subject matter jurisdiction over Plaintiffs' complaint at the time it was filed, as Conn. Gen. Stat. 45a-363 provides the superior court a limited grant of jurisdiction over a complaint filed pursuant to that statute, even if the claim is not ripe when filed. View "Keller v. Beckenstein" on Justia Law

At issue in this appeal was Conn. Gen. Stat. 21-80a, which protects residents of mobile manufactured home parks by limiting the availability of summary process actions. Under the statute, if a resident proves that he or she engaged in one or more of the protected activities enumerated in the statute within the six months preceding the park owner's eviction proceeding, the owner may not maintain a summary process action against that resident unless the owner can show that one of the exceptions specified in the statute applies. Defendants, residents of a mobile manufactured home park owned by Plaintiff, appealed from the judgment of the appellate court affirming the trial court's judgment of possession in favor of Plaintiff, claiming that judgment of possession should be granted in their favor because Plaintiff's summary process action was barred under section 21-80a. The Supreme Court affirmed, holding (1) defendants were in material noncompliance with the lease and were using the dwelling unit or the premises for a purpose which was in violation of the rental agreement; and (2) thus, the appellate court's ultimate conclusion that Defendants' violation was encompassed by 21-80a was proper. View "Fairchild Heights, Inc. v. Dickal" on Justia Law

The parcel of land that was the subject of this appeal was once owned by a school. An adjacent property, now owned by Defendants, Eric and Wendy Federer, was previously owned by Wendy's father. In 1990, the school sold its property to a limited liability corporation subject to a set of restrictive covenants that did not expressly reference any third parties. The present action arose when Plaintiff, the current owner of the property, sought permits to develop the school property in a manner inconsistent with the terms of the restrictive covenants. Plaintiff filed a declaratory judgment action seeking to establish the unenforceability of the restrictive covenants as to Defendants. Defendants counterclaimed, seeking to quiet title to Plaintiff's property and to enforce the restrictive covenants. The trial court granted summary judgment in favor of Plaintiff. The Supreme Court reversed, holding (1) the covenants at issue in this case were not void as a matter of law; and (2) questions of material fact existed as to whether Defendants were entitled to enforce them. Remanded. View "Wykeham Rise, LLC v. Federer" on Justia Law

Defendant Anthony Thompson was convicted of one count of murder and two counts of assault in the first degree. The Supreme Court affirmed, holding (1) the trial court applied the proper standard in admitting into evidence a statement to the police and a signed photographic array by a deceased eyewitness identifying Defendant as the shooter; (2) there was sufficient evidence to support the trial court's finding that Defendant had caused the death of the witness; and (3) even if the trial court improperly admitted evidence relating to the circumstances surrounding the death of the witness to show consciousness of guilt, the impropriety was harmless. View "State v. Thompson" on Justia Law

Plaintiff commenced a dissolution of marriage action from Defendant. Defendant, however, was never served process. The commissioner of social services, meanwhile, filed a support petition against Defendant that was assigned the same docket number as the dissolution action. Defendant was served process for the support action, and Defendant's counsel filed an appearance in the support action. The trial court relied on Defendant's failure to file a motion to dismiss the dissolution action within thirty days of filing the appearance in the support action in concluding that Defendant had waived any challenge to personal jurisdiction in the dissolution action. The appellate court vacated the trial court on basis that there was no personal jurisdiction over Defendant. The Supreme Court reversed, holding (1) the appellate court erred in giving retroactive effect to Practice Book 25a-3(f), which provides that all appearances entered on behalf of parties for matters involving Title IV-D child support matters shall be for those matters only; and (2) the trial court properly relied on Practice Book 3-3(2) in concluding that Defendant filed an appearance in the dissolution action. Remanded. View "Narayan v. Narayan" on Justia Law

Plaintiff Christine Sapko sought survivor's benefits following the death of her husband, an employee of the state of Connecticut. The workers' compensation commissioner denied Plaintiff's claim, determining that the decedent's ingestion of Oxycodone and Seroquel constituted a superseding cause of his death and, therefore, the decedent's compensable work injuries were not the proximate cause of his death. The workers' compensation review board upheld the commissioner's decision. The appellate court affirmed, concluding (1) the board incorrectly concluded that the superceding cause doctrine applied to the present case, but (2) this impropriety was harmless because the board correctly determined that the commissioner properly decided the issue of proximate cause. The Supreme Court affirmed but for different reasons, holding that the board correctly concluded that the commissioner's finding that superseding events broke the chain of proximate causation between the decedent's compensable work injuries and his death constituted a proper application of the law to the facts. View "Sapko v. State" on Justia Law

In this case a jury found that Marc Pascual hired Defendant Eduardo Santiago to murder the victim and that Defendant acted in concert with Matthew Tyrell to break into the victim's home and fatally shoot him. The jury then returned a verdict finding Defendant guilty of all the charged offenses in the ten count information, including capital felony. The trial court sentenced Defendant to death by lethal injection. The Supreme Court (1) affirmed the underlying judgment of conviction; but (2) reversed the judgment insofar as it imposed a sentence of death, holding that the trial court did not err when it reviewed the department of children and families' file in camera, but the scope of its review failed to disclose significant and relevant mitigating evidence, requiring that Defendant receive a new penalty phase hearing. Remanded to the trial court for a new penalty phase hearing, following a new in camera review of the department's files and disclosure of evidence material to Defendant's case in mitigation. View "State v. Santiago" on Justia Law

Following a jury trial, Defendant Daniel Golodner was convicted of two counts of interfering with an officer and two counts of reckless endangerment in the second degree in connection with a dispute over a neighbor's attempt to have their common property boundary surveyed. The Supreme Court affirmed the judgment in part and reversed the judgment in part with respect to the conviction on the second charge of reckless endangerment, holding that the trial court improperly denied Defendant's motion to dismiss the second charge of reckless endangerment for violation of the statute of limitations. Remanded with direction to render judgment of acquittal on that charge and for resentencing. View "State v. Golodner" on Justia Law

After a jury trial, Defendant Francisco Pascual was convicted of several charges relating to his alleged attempt to sexually assault a twelve-year-old girl from El Salvador after the victim illegally crossed the border from Mexico into the United States. Defendant appealed, claiming that the trial court improperly (1) admitted hearsay evidence that, several days before the charged events, the victim was told about a threat made by an unidentified third party, and (2) instructed the jury that the threat evidence was admitted to show that the victim reasonably feared Defendant in order to prove sexual assault and kidnapping charges. The Supreme Court affirmed, holding that, even if the trial court improperly admitted the evidence and gave improper instructions to the jury, Defendant was not entitled to a new trial because the purported improprieties were not harmful. View "State v. Pascual" on Justia Law

Following a jury trial, Defendant Kenneth John Otto, Sr. was convicted of murder and tampering with evidence. Defendant appealed. The Supreme Court affirmed the judgment of the trial court, holding (1) there was sufficient evidence to prove the element of specific intent necessary to support the murder conviction; and (2) in closing arguments the prosecutor did not improperly invite the jury to apply an incorrect legal standard or improperly suggest that the jury could find Defendant guilty of murder even if it did not find that he had the requisite intent to kill, simply to punish him for destroying evidence. View "State v. Otto" on Justia Law