Justia Connecticut Supreme Court Opinion Summaries

Articles Posted in Constitutional Law
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These two consolidated appeals arose from the collision of two city fire trucks. As a result of the collision, firefighter John Keane died, and firefighter William Mahoney suffered serious injuries. Monica Keane brought an action against Defendants, the firefighters who drove the trucks, alleging negligence in their operation of the fire trucks and that their negligence caused John Keane's death. In the second case, William and Erin Mahoney filed a complaint against Defendants, two firefighters and the city, alleging that the firefighters were negligent and that their negligence caused William Mahoney to sustain injuries. In both cases, the trial court granted the motions of Defendants to strike all counts of the complaint, concluding that Conn. Gen. Stat. 7-308 barred firefighters who are eligible to receive workers' compensation benefits from bringing negligence actions against other firefighters for their injuries. The Supreme Court affirmed the judgments of the trial court, holding that section 7-308 does not violate equal protection and, therefore, the trial court properly granted Defendants' motions to strike on the ground that the actions were barred by the immunity provision in section 7-308. View "Keane v. Fischetti" on Justia Law

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Following a jury trial, Defendant John Papandrea was convicted of nine counts of larceny in the first degree. The appellate court affirmed. At trial, the state claimed that Defendant stole corporate funds from his employer in order to purchase artwork. Defendant conceded that he took the funds but asserted in his defense that he lacked the wrongful intent necessary for first degree larceny. At issue on appeal was whether the appellate court properly concluded that the State had presented sufficient evidence of Defendant's intent to commit larceny. The Supreme Court affirmed, concluding that the evidence was sufficient to permit the jury to find that Defendant had the necessary intent to commit larceny. View "State v. Papandrea" on Justia Law

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For several years, Plaintiff Housatonic Railroad Company purchased diesel fuel from a petroleum distributor that was used exclusively by Plaintiff as part of its interstate freight rail business. The distributor remitted the petroleum tax to Defendant, the commissioner of revenue services. The distributor separately billed Plaintiff for the amount of tax it paid to the department of revenue services, and Plaintiff paid that amount directly to the distributor. Plaintiff then submitted requests to the department for a refund of the money paid for the petroleum tax by the distributor to the department. The commissioner denied Plaintiff's request. Plaintiff appealed. The trial court granted Defendant's motion to dismiss, concluding that the state was immune from suit because Plaintiff could not establish an exception to sovereign immunity under any of three separate statutory provisions. The Supreme Court affirmed, holding that none of the statutory provisions on which Plaintiff relied permits a rail carrier to bring an action against the state for a refund of taxes paid by a petroleum distributor. View "Housatonic R.R. Co. v. Comm'r of Revenue Servs." on Justia Law

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Petitioners, George Gould and Ronald Taylor, were arrested and charged with, inter alia, murder, felony murder, and robbery in the first degree. The jury acquitted Petitioners of the murder charge but convicted them on all of the other counts. Subsequently, Petitioners filed petitions for writs of habeas corpus, alleging ineffective assistance of counsel and actual innocence. The habeas court granted the petitions and vacated the convictions, concluding that petitioners had established their entitlement to relief on the basis of actual innocence because two of the state's witnesses had recanted their testimony. Respondent, the commissioner of correction, appealed. The Supreme Court reversed the habeas court's judgments, holding that, under the test set forth in Miller v. Commissioner of Correction, actual innocence requires affirmative evidence that Petitioners did not commit the crimes of which they were convicted, not simply the discrediting of evidence on which the conviction rested. Remanded for a new trial under the proper standard. View "Gould v. Comm'r of Correction" on Justia Law

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In four decisions, Defendant, the freedom of information commission, ordered Plaintiff, a town ethics commission, to make and maintain, for three years, audio recordings of Plaintiff's executive sessions or any other session closed to the public after finding that (1) Plaintiff violated the open meetings provision of the Freedom of Information Act by convening in nonpublic sessions to discuss certain matters and (2) Plaintiff had failed to comply with the commission's orders to amend its minutes to reflect those discussions. The trial court consolidated Plaintiff's appeals and then dismissed them. The Supreme Court reversed, holding that the commission's orders exceeded its remedial authority under the Freedom of Information Act. Remanded with direction to render judgments in favor of Plaintiff. View "Ethics Comm'n v. Freedom of Info. Comm'n" on Justia Law

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After a jury trial, Defendant was convicted of one count each of possession of narcotics, possession of a controlled substance, interfering with an officer, and tampering with physical evidence. The Supreme Court affirmed, holding that the trial court did not abuse its discretion in (1) denying Defendant's motion to suppress certain evidence taken from the motor vehicle that Defendant was operating at the time of his arrest; (2) concluding that there was sufficient evidence to sustain Defendant's conviction on the possessory charges; (3) admitting Defendant's unredacted medical records into evidence; and (4) instructing the jury as to the State's burden of proof. View "State v. Winfrey" on Justia Law

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Defendant pled guilty to sexual assault in the second degree, sexual assault in the third degree, and risk of injury to a child. The Supreme Court twice remanded the case to the trial court for resentencing. At the hearing for resentencing upon the second remand, Defendant moved to withdraw his prior pleas, and the trial court denied his motion. On appeal, Defendant claimed the trial court should have granted his motion pursuant to Practice Book 39-26 and 39-27(2) as well as due process protections because the Supreme Court previously determined that his plea agreement resulted in an unenforceable illegal sentence. The Supreme Court reversed and remanded with direction to dismiss Defendant's motion to withdraw his pleas, holding that Defendant's motion was beyond the scope of remand for resentencing and therefore should have been dismissed for lack of subject matter jurisdiction. View "State v. Tabone" on Justia Law

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Defendant pleaded guilty to two counts of possession of child pornography. As a condition of probation, Defendant was required to not possess or subscribe to any sexually stimulating material deemed inappropriate by probation officer. After finding Defendant violated his probation by visiting dating websites and possessing nude photographs, the trial court revoked Defendant's probation. On appeal, Defendant claimed that the special condition was unconstitutionally overbroad and vague on its face and unconstitutionally vague as applied to him, and that the evidence was insufficient to support the trial court's finding. The Supreme Court affirmed, holding (1) Defendant's claim of unconstitutional overbreadth failed because because he did not allege a violation of his First Amendment rights; (2) there was no merit to Defendant's vagueness claim, and his as-applied vagueness claim failed under State v. Golding and the plain error doctrine; and (3) there was sufficient evidence in the record to support the trial court's finding. View "State v. Stephens" on Justia Law

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Defendant was adjudicated a youthful offender for committing the crime of criminal trespass in the second degree. The trial court sentenced Defendant to ninety days' incarceration and a period of probation of two years. As a condition of probation, Defendant was ordered to make restitution to the victims in the amount of $2,000. Defendant appealed, arguing that since there was no evidence or finding that he had personally caused damage, the trial court's order to pay restitution was improper. The appellate court reversed the sentence imposed and remanded with direction to vacate the restitution order. The Supreme Court reversed, holding that the trial court did not abuse its discretion because its order of restitution had a nexus to the crime of which Defendant was convicted and was, therefore, reasonably related to Defendant's rehabilitation. View "State v. Silas S." on Justia Law

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Defendant David Sheriff was charged with several drug-related offenses. Flavio Bail Bonds executed a bail bond for Sheriff on each of the cases. After Sheriff failed to appear for the trial of the three cases, Flavio discovered that Sheriff had fled to Jamaica and remained there. The state subsequently declined to initiate extradition proceedings. Flavio filed a petition with the trial court for compromise or to release Flavio from its obligation on the bonds pursuant to Practice Book 38-23, which permits a court to relieve a surety of bond obligations after a showing of good cause. The trial court determined that Flavio had failed to establish good cause, and therefore, denied Flavio's petition. Flavio thereafter filed a writ of error. The Supreme court held that the trial court properly denied the petition and denied the writ, holding (1) the trial court applied the proper standard in making its determination, and (2) the trial court properly concluded that Flavio failed to show good cause under the rule. View "State v. Sheriff" on Justia Law