Justia Connecticut Supreme Court Opinion Summaries

Following a jury trial, Defendant Sheri Paige, then an attorney, was convicted of nine charges relating to the theft of assets from an elderly client, including one count of perjury. With respect to the perjury instruction, although Defendant had submitted a request to charge the jury that it must decide whether a particular statement at issue was material and the State had conceded that it was improper for the trial court to have instructed the jury that the State had proven this element as a matter of law, the appellate court determined that Defendant had waived her right to challenge the instruction that was given. The Supreme Court reversed the judgment in part, holding that the appellate court erred in determining that Defendant had waived her right to challenge the instruction. Remanded for a new trial on the charge of perjury. View "State v. Paige" on Justia Law

After a jury trial, Defendant John Jackson was convicted of murder. The Supreme Court affirmed the judgment of conviction, holding that the trial court did not err in denying (1) Defendant's motion to suppress certain evidence seized by the police without a search warrant, as Defendant had abandoned his expectation of privacy with respect to the seized items; (2) Defendant's motion to preclude certain evidence that the state had disclosed in an untimely manner, as Defendant established neither that there were exceptional circumstances requiring preclusion nor that he would have been prejudiced by the late disclosure; (3) Defendant's motion to suppress certain statements that he gave to the police, as Defendant was not in custody when he made the statements and the statements were voluntary; and (4) denying Defendant's request to give a jury instruction on third party culpability, as the evidence did not support the instruction. View "State v. Jackson" on Justia Law

The State filed an application for an arrest warrant for Defendant, alleging a charge of kidnapping in the first degree for the purpose of committing a sexual assault. The trial court ordered that the affidavit supporting the arrest warrant, which recounted statements of the victim and other individuals regarding the incident, be sealed for fourteen days. The victim requested that the affidavit remain sealed indefinitely, citing her right to be treated with fairness and respect throughout the criminal justice process under the state's victims rights amendment. The trial court denied the victim's motion. The Supreme Court dismissed the victim's appeal without reaching its merits, holding that the victim lacked standing to pursue the appeal, as nothing in the victims rights amendment itself or in subsequently enacted legislation explicitly makes victims parties to criminal prosecutions or otherwise affords them rights to appeal. View "State v. Gault" on Justia Law

In the involuntary conservatorship action underlying this case, Daniel Gross was placed in the locked ward of Grove Manor Nursing Home. Jonathan Newman was appointed by the probate court to represent Gross in the action, and Kathleen Donovan was appointed as conservator. The superior court granted Gross's petition for writ of habeas corpus, finding that the conservatorship was void ab initio. Gross subsequently brought a complaint in U.S. District Court, asserting state and federal civil rights claims. The court dismissed it as to all defendants, finding, in relevant part, that Donovan, Newman, and Grove Manor were entitled to immunity because they were serving the judicial process. On appeal, the U.S. court of appeals submitted certified questions regarding Connecticut law to the Supreme Court. The Court held (1) absolute quasi-judicial immunity extends to a conservator appointed by the probate court only when the conservator is executing an order of the probate court or the conservator's actions are ratified by the probate court; (2) absolute quasi-judicial immunity does not extend to attorneys appointed to represent respondents in conservatorship proceedings or conservatees; and (3) the function of nursing homes caring for conservatees does not entitle them to quasi-judicial immunity under any circumstances. View "Gross v. Rell" on Justia Law

Following a jury trial, Defendant Willie Coleman was convicted of murder in connection with the fatal stabbing of his girlfriend. Defendant appealed, contending that the state offered insufficient evidence to prove beyond a reasonable doubt his intent to kill the victim, that the trial court improperly instructed the jury that it could infer such intent from the number of wounds he had inflicted on her, and that an improper statement by the prosecutor in closing argument deprived him of a fair trial. The Supreme Court affirmed, holding (1) the evidence was sufficient in this case to demonstrate intent; (2) Defendant failed to preserve his claim challenging the jury instructions, and Defendant could not prevail under State v. Golding or the plain error doctrine; and (3) under the circumstances of this case, the prosecutor's remark in closing argument did not deprive Defendant of a fair trial. View "State v. Coleman" on Justia Law

Defendant William Coleman was serving a fifteen-year sentence following his convictions on charges pertaining to his relationship with his ex-wife when he went on a hunger strike. Following a trial, the trial court granted the former commissioner of correction's application for a permanent injunction authorizing the department of correction to restrain and force-feed Defendant to prevent life-threatening dehydration and malnutrition. Defendant was subsequently force-fed. The Supreme Court affirmed, holding that the trial court properly determined (1) the state's interests outweighed Defendant's common-law right to bodily integrity; (2) the forcible administration of artificial nutrition and hydration to Defendant did not violate his constitutional right to free speech and privacy; and (3) international law did not prohibit medically necessary force-feeding under such circumstances. View "Comm'r of Corr. v. Coleman" on Justia Law

The local board of education of the City of Bridgeport passed a resolution requesting the state board of education to authorize the commissioner of education to reconstitute the local board. The state board voted to authorize the commissioner to reconstitute the local board. In three separate actions, former local board members and residents and electors of the City filed actions against the state board, local board, and others, alleging state statutory and constitutional violations. The trial court reserved the action for the advice of the Supreme Court. At issue was (1) whether the failure of the state board to require the local board to undergo and complete training, as mandated by Conn. Gen. Stat. 10-223e(h), rendered void the state board's authorization; and (2) whether the local board's resolution requesting that the state board authorize reconstitution resulted in a waiver of the state board's obligation to require training. The Supreme Court concluded (1) the state board's failure to require training rendered void its authorization of reconstitution under section 10-223e(h); and (2) the local board's resolution had no effect on the operation of the statute. View "Pereira v. State Bd. of Educ." on Justia Law

A jury found Defendant guilty of four drug-related crimes. The appellate court concluded that there was insufficient evidence to support Defendant's conviction of possession of narcotics with intent to sell within 1500 feet of a school in violation of Conn. Gen. Stat. 21a-278a(b) and possession of drug paraphernalia with intent to use within 1500 feet of a school in violation of Conn. Gen. Stat. 21a-267(c) and remanded the case, directing the trial court to render judgment of not guilty on these charges. The Supreme Court affirmed in part and reversed in part, holding that the appellate court (1) properly held that there was insufficient evidence to support Defendant's conviction under section 21a-278a(b), but (2) improperly held that there was insufficient evidence to support Defendant's conviction under section 21a-267(c). Remanded for a new trial on the charge of possession of drug paraphernalia with the intent to use within 1500 feet of a school. View "State v. Lewis" on Justia Law

Plaintiff, the former town clerk of the town of Watertown, was removed from her position after she failed to report for work. Plaintiff subsequently filed a complaint against the town and certain of its officials (1) seeking a writ of mandamus ordering Defendants to restore her salary and benefits from the time they were discontinued and to continue such payments for the duration of her term, (2) claiming Defendants had violated her constitutional rights pursuant to 42 U.S.C. 1983, and (3) seeking recovery of her lost salary. The trial court granted Plaintiff's motion for partial summary judgment on counts one and three. The court, however, rendered judgment in favor of defendants on count two of the complaint based upon the jury's finding that there had not been a constitutional violation of due process. The Supreme Court reversed the judgment in part and remanded the case for further proceedings on counts one and three, holding that the trial court improperly concluded that Plaintiff had a clear legal right to be paid for the balance of her elected term unless or until she was removed from office. View "Stewart v. Watertown" on Justia Law

Plaintiffs, the town of Bozrah and the town's zoning enforcement officer, brought an action seeking a temporary and permanent injunction to enjoin Defendants, owners and residents of certain property, from refusing to consent to an inspection of their property for zoning violations. The trial court granted a temporary injunction preventing Defendants from refusing to allow the inspection, concluding that pursuant to Camara v. Municipal Court, the reasonable governmental interest in stabilizing property values and promoting the general welfare justified an inspection in the present action. Defendants appealed, claiming that the trial court's order violated their right to be free from unreasonable searches and seizures. The Supreme Court reversed, holding (1) a zoning official may inspect a single property pursuant to Conn. Gen. Stat. 8-12 if the official first obtains an injunction issued upon probable cause by a judicial officer; and (2) because the trial court failed to make a preliminary determination of probable cause to believe that a zoning violation existed on the property, its order permitting a search of Defendants' property violated the Fourth Amendment. Remanded. View "Bozrah v. Chmurynski" on Justia Law