Justia Connecticut Supreme Court Opinion Summaries

Plaintiff, a construction company, agreed by contract to perform site work for Hoffman Enterprises on several parcels of property. Plaintiff later filed this action against Hoffman Enterprises and Jeffrey Hoffman for negligent misrepresentation, among other claims. The trial court granted Hoffman's motion to strike the negligent misrepresentation claim. The appellate court reversed. Hoffman appealed, asserting that Plaintiff could not, as a matter of law, satisfy the detrimental reliance element of its claim because Hoffman's apparent authority to bind Hoffman Enterprises contractually meant that Plaintiff could not have relied to its detriment on Hoffman's statements. The Supreme Court affirmed, holding (1) the fact that allegations pleaded in a complaint might also state a contractual claim against a corporate entity under the apparent authority doctrine does not preclude a separate claim of negligent misrepresentation against a principal of that corporate entity as a matter of law; and (2) Plaintiff pleaded a legally sufficient claim of negligent misrepresentation. View "Coppola Constr. Co. v. Hoffman Enters. Ltd. P'ship" on Justia Law

Plaintiff was injured when she rode her bicycle into a pipe gate on property maintained by Defendant, a water supply company. Plaintiff brought this action claiming that Defendant was negligent in its maintenance of the gate. After a trial, the jury awarded damages to Plaintiff. Defendant appealed, claiming that no reasonable juror could have found that the alleged negligence had an "inherently close connection" to Defendant's proprietary function of supplying water and that, in the alternative, it was entitled to immunity under the Recreational Land Use Act. The Supreme Court affirmed, holding (1) Defendant was liable because the maintenance of the gate was inextricably linked to a proprietary function; and (2) Defendant was not entitled to immunity pursuant to the Act. View "Blonski v. Metro. Dist. Comm'n" on Justia Law

Doctor was a physician who worked for Hospital on a study he claimed would assist in the treatment of children with abnormally low rates of growth. In actuality, Doctor was a child pornographer and pedophile and used the study as a cover to recruit and sexually exploit hundreds of children. The named plaintiff (Plaintiff), one of the exploited children, brought this action against Hospital alleging (1) Hospital negligently failed to supervise Doctor's activities in connection with the study, and (2) Hospital breached the special duty of care it owed to children in its custody. The trial court rendered judgment for Plaintiff on both claims and awarded him $2,750,000. The Supreme Court affirmed, holding that the trial court did not err in its instructions to the jury. View "Doe v. Saint Francis Hosp. & Med. Ctr." on Justia Law

Upon Plaintiff and Defendant's divorce, the trial court ordered Plaintiff to pay Defendant unallocated alimony and child support for fourteen years, concluding that Plaintiff had an earning capacity far Plaintiff his current income. After Plaintiff obtained employment, Father filed a motion to modify the child support order, contending that his current salary constituted a fraction of the earning capacity previously attributed to him by the trial court. The trial court denied Plaintiff's motion without specifying the amount of Plaintiff's estimated earning capacity. The appellate court affirmed. The Supreme Court reversed, holding (1) when a trial court has based a financial award on a party's earning capacity, the court must determine the specific dollar amount of the party's earning capacity; and (2) because the trial court in this case could not reasonably have concluded there had been no substantial change in Plaintiff's earning capacity between the time of the original financial award and the motion for modification without having determined Plaintiff's specific earning capacity, the court erred when it denied the motion for modification. Remanded for a new hearing on Plaintiff's motion for modification. View "Tanzman v. Meurer" on Justia Law

Plaintiff appealed the town assessor's interim valuations of his property. The Board of Assessment Appeals upheld the assessor's interim valuations. The trial court concluded (1) the assessor improperly relied on Conn. Gen. Stat. 12-55 as authority to conduct the interim assessments and that she should have been guided by Conn. Gen. Stat. 12-53a instead; and (2) because section 12-53a only applied to "completed new construction," the assessor did not have authority to assign value to partially completed construction on the grand lists. The Supreme Court reversed, holding (1) section 12-55 provides assessors with broad authority to conduct interim assessments of real property, and the plain language of section 12-53a is applicable only to completed new construction; and (2) therefore, the assessor had the authority, pursuant to section 12-55, to conduct the interim assessments of Plaintiff's property and to assign value to the partially completed construction. View "Kasica v. Town of Columbia" on Justia Law

Employee was injured at Employer's paper bag manufacturing facility while attempting to dislodge a bag that was jammed in a machine. Employee filed this action to recover damages for the alleged intentional misconduct by his night supervisor (Supervisor), claiming that his injuries resulted from Employer's modification of the machine and that Supervisor was Employer's alter ego for the purposes of the intentional tort exception to the Workers' Compensation Act's (Act) exclusivity provisions. The trial court granted summary judgment for Employer, concluding that the Act was Employee's exclusive remedy. At issue on appeal was whether Supervisor was Employer's alter ego under the exception to the exclusivity of the Act for intentional torts committed by a fellow employee identified as the alter ego of the corporation. The Supreme Court affirmed, holding that Employee failed to establish a disputed issue of fact as to whether Supervisor was Defendant's alter ego. View "Patel v. Flexo Converters U.S.A., Inc." on Justia Law

Plaintiff filed this action for trespass after Defendant removed multiple trees on Plaintiff's property without Plaintiff's permission. The trial court rendered judgment in favor of Plaintiff and awarded damages reflecting the diminution in the value of Plaintiff's land as a result of the removal of the trees. The appellate court affirmed. Defendant appealed, contending that the appellate court improperly determined that Conn. Gen. Stat. 52-560, which Defendant claimed provides the exclusive measure of damages in a tree cutting case, does not preempt a common-law cause of action for intentional trespass under the circumstances here. The Supreme Court affirmed, holding that the appellate court properly concluded that section 52-560 does not preempt the common law but, rather, enhances the common law by providing for treble damages when the proper measure of damages is the reasonable value of the trees as timber. View "Caciopoli v. Lebowitz" on Justia Law

After a jury trial, Defendant was convicted of one count of criminally negligent homicide, two counts of cruelty to persons, and two counts of risk of injury to a child. The convictions arose from Defendant's restriction of fluids to a two-year-old child in order to correct certain behavioral problems. The child died of dehydration. Due to her low IQ, Defendant did not know that withholding liquids could cause the child to die, but Defendant did understand that depriving someone of fluids could cause dehydration. The appellate court affirmed the convictions. The Supreme Court affirmed, holding that the appellate court properly determined that the State presented sufficient evidence Defendant had the required mental state in order to convict her of the offenses. View "State v. Patterson" on Justia Law

In 2003, multiple residents of a nursing home (Greenwood) died or were injured when another resident set fire to the facility. Consequently, thirteen negligence actions seeking damages for serious bodily injury or wrongful death were filed against Greenwood, the owner of the property housing Greenwood, the lessee of the property (Lexington Healthcare), and the operator of Greenwood. Plaintiff issued a general liability and professional liability insurance policy to Lexington Healthcare. At issue in this case was the amount of liability insurance coverage available for the claims. The trial court determined the amount available under the policy and rendered judgment accordingly. The Supreme Court reversed in part, holding (1) the trial court improperly interpreted a policy endorsement in the policy relating to the aggregate policy limit; and (2) the trial court improperly applied a self-insured retention endorsement to reduce the available coverage. Remanded. View "Lexington Ins. Co. v. Lexington Healthcare Group, Inc." on Justia Law

After a jury trial, Defendant was convicted of, inter alia, promoting a minor in an obscene performance, risk of injury to a child, and possession of child pornography in the third degree. Defendant appealed, contending that the trial court erred in denying his motion to suppress evidence obtained from his Gmail account through the execution of a search warrant. Specifically, Defendant argued that the warrant was an extraterritorial search warrant for his Gmail account contained on Google's servers located in California. The Supreme Court affirmed without reaching the merits of Defendant's argument, holding that any impropriety in the issuance and execution of the warrant was, beyond a reasonable doubt, harmless error that did not affect the verdict. View "State v. Esarey" on Justia Law