Justia Connecticut Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of several crimes. The trial court enhanced Defendant's sentence for being a persistent dangerous felony offender in violation of Conn. Gen. Stat. 53a-40. On appeal, the Supreme Court concluded that section 53a-40(h) was unconstitutional to the extent it required the trial court to make the requisite finding that Defendant's extended incarceration would best serve the public interest. On remand, the jury found that extended incarceration of Defendant would best serve the public interest, and the trial court again imposed an enhanced sentence pursuant to section 53a-40. The Supreme Court affirmed, holding that the trial court did not err in (1) denying Defendant's motion to dismiss the information because the retroactive application to Defendant of section 53a-40(h), as modified by the constitutional gloss that the Court placed on it before remand, did not violate the ex post facto clause of the Fourteenth Amendment; (2) construing the term "public interest," as used in section 53a-40(h), to exclude consideration of the costs of incarceration; (3) precluding Defendant from introducing expert testimony about his anticipated release date from a concurrent federal sentence; and (4) admitting evidence of the details of the victim's injuries. View "State v. Bell" on Justia Law

Plaintiff filed a claim for workers' compensation benefits for injuries she sustained while working for Employer. The workers' compensation commissioner awarded Plaintiff total disability benefits and reimbursement for certain prescription medication payments and mileage under the Workers' Compensation Act. The compensation review board affirmed but remanded for a determination of the specific amounts to be reimbursed to Plaintiff. Defendants, Employer and Insurer, appealed the commissioner's supplemental findings and award. The appellate court dismissed the appeal for lack of subject matter jurisdiction, concluding that Conn. Gen. Stat. 31-301(a) required Defendants to appeal to the board. The Supreme Court reversed, holding that the appellate court had jurisdiction over the appeal because the jurisdictional requirements of Conn. Gen. Stat. 31-301(b), which governs appeals from the board to the appellate court, were fully satisfied in this case. View "O'Connor v. Med-Center Home Health Care, Inc." on Justia Law

Defendant Anna Miller executed a promissory note to a finance company and conveyed by way of a mortgage her interest in real property to Mortgage Electronic Registration Systems. Defendant's mortgage was thereafter assigned to Plaintiff, RMS Residential Properties (RMS), which became the holder of the note prior to the commencement of this foreclosure action. The trial court granted summary judgment in favor of Plaintiff. On appeal, Defendant contended that RMS lacked standing to commence the foreclosure action because there was no statutory authority that conferred standing on a mere holder of a note to foreclose a mortgage. The Supreme Court affirmed, holding that because Conn. Gen. Stat. 49-17 raises a rebuttable presumption that a holder of a note is the owner of the debt, the statute may confer standing to foreclose a mortgage on a holder of a note. View "RMS Residential Properties, LLC v. Miller" on Justia Law

Plaintiff, a development company, brought an action against Defendants, several entities including the City, alleging Defendants had violated the Connecticut Antitrust Act by engaging in an illegal conspiracy in restraint of trade. The trial court granted Defendants' motion to strike Plaintiff's amended complaint on the ground that the complaint failed to allege an antitrust injury. The appellate court affirmed. The Supreme Court affirmed, holding that Plaintiff's allegation that Defendants took bribes and kickbacks in exchange for steering public contracts did not state a cognizable antitrust claim, and therefore, the appellate court and trial court properly granted Defendants' motions to strike Plaintiff's amended complaint. View "Bridgeport Harbour Place I, LLC v. Ganim" on Justia Law

Defendant pleaded guilty to murder and capital felony and was sentenced to death. The case was remanded for a new penalty phase hearing, during which Defendant waived his right to have a jury determine his sentence. After the hearing, a three-judge panel again sentenced Defendant to death. The Supreme Court affirmed the sentence, holding (1) Defendant's waiver of a jury for the penalty phase hearing was constitutionally valid; (2) the presiding judge at the penalty phase hearing did not make comments that warranted recusal, and his involvement in earlier proceedings did not give rise to an improper appearance of impartiality; (3) Defendant failed to establish that the absence of a specific intent requirement in the aggravating factor found by the panel rendered his death sentence unconstitutional; (4) the evidence was sufficient to support the panel's finding of an aggravating factor; (5) the panel properly weighed aggravating and mitigating factors and determined that death was the appropriate punishment; (6) Defendant failed to establish that his sentence was the product of passion, prejudice and other arbitrary factors; and (7) the death penalty, as a general matter, does not violate the state constitution. View "State v. Rizzo" on Justia Law

Defendant was convicted of assault in the third degree and sentenced to one-year incarceration, execution suspended, and three years probation. Defendant was later arrested and charged with risk of injury to a child and, subsequently, with violation of probation. The trial court revoked Defendant's probation on the basis of its finding that Defendant had committed the crime of risk of injury to a child, and committed Defendant to the custody of the commissioner of correction for the unexecuted portion of his original one-year sentence. The appellate court affirmed. The Supreme Court reversed, holding that the appellate court improperly concluded that there was sufficient evidence that Defendant violated his probation by committing the crime of risk of injury to a child when he failed to supervise a two-year-old who was in his care and able to exit the home. Remanded with direction to render judgment for Defendant. View "State v. Maurice M." on Justia Law

Plaintiff, while in the course of employment as a uniformed police officer of the City's police department, was involved in a shooting and was later criminally charged in connection with the shooting. The City suspended Plaintiff without pay pending the outcome of the criminal matter. After being acquitted of all charges, Plaintiff brought an action against the City seeking reimbursement for legal fees, lost wages and lost employment benefits. The trial court awarded Plaintiff $562,277, which included Plaintiff's attorney's fees. The Supreme Court affirmed, holding (1) the trial court's finding of a contract between Plaintiff and his lawyer in which Plaintiff incurred legal fees beyond the retainer was not clearly erroneous; (2) the trial court did not abuse its discretion in awarding damages to Plaintiff for attorney's fees, and the award was not excessive; and (3) Plaintiff was entitled to damages for economic loss during his entire suspension, and the trial court's award of damages for economic loss in this case was proper. View "Murtha v. City of Hartford" on Justia Law

Plaintiff sued Defendants, the driver of a vehicle and the vehicle's owner, for negligence after the driver of the vehicle struck Plaintiff's vehicle, causing injuries to Plaintiff. Plaintiff submitted an offer of compromise to Defendants, proposing to settle the case. Defendants did not accept the offer during the statutory period under Conn. Gen. Stat. 52-192a. Later, the trial court granted Defendants' motion to strike the offer of compromise as a sanction for a discovery violation. A jury returned a verdict in favor of Plaintiff, and the trial court then denied Plaintiff's posttrial motion for offer of compromise interest. The Supreme Court reversed in part, holding the trial court's striking of the offer of compromise was within the scope of its judicial authority, but doing so in this case was an abuse of discretion because nothing in the record warranted the sanction in the absence of a finding of bad faith or significant prejudice. Remanded with direction to grant Plaintiff's motion for offer of compromise interest. View "Yeager v. Alvarez" on Justia Law

Plaintiff and his wife (Wife) sued Defendant for negligence and loss of consortium after Defendant's vehicle struck Plaintiff's vehicle and injured Wife. Wife subsequently withdrew her claims pursuant to a settlement agreement she entered into with Defendant, and Plaintiff withdrew his negligence claim. The trial court rendered judgment for Defendant on Plaintiff's remaining claim, concluding that Plaintiff's loss of consortium claim was barred by the settlement of Wife's negligence claim. The Supreme Court affirmed, holding (1) pursuant to legally binding precedent, because a consortium claim is derivative of the injured spouse's cause of action, the consortium claim is barred when the suit brought by the injured spouse has been terminated by settlement; and (2) strong policy reasons support the application of this rule to claims such as Plaintiff's. View "Voris v. Molinaro" on Justia Law

Defendant Gary Gibson was convicted, after a jury trial, of failure to appear in the first degree. The appellate court reversed the conviction on the ground that improper statements by the prosecutor during closing argument had deprived Defendant of his constitutional due process right to a fair trial. The Supreme Court reversed in part, holding that the trial prosecutor's two uses of the words 'I think' while marshaling the evidence during closing argument did not constitute an improper expression of personal opinion and therefore did not amount to prosecutorial impropriety. Remanded with direction to affirm the judgment of conviction on the charge of failure to appear. View "State v. Gibson" on Justia Law