Justia Connecticut Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the appellate court concluding that No. 17-4, 1 of the 2017 Special Acts (S.A. 17-4) was an unconstitutional public emolument in violation of Conn. Const. Art. I, 1 because it did not serve a legitimate public purpose, holding that the appellate court did not err.The State brought this action seeking a judgment declaring that S.A. 17-4, pursuant to which the General Assembly extended the time limitation for Defendants to bring their action against the State for injuries arising from poor air quality at public schools, constituted an unconstitutional public emolument. The trial court granted summary judgment for the State. The appellate court affirmed. Defendants appealed, arguing that the appellate court failed to consider whether the State met its burden of proving that the General Assembly's "sole objective" in acting S.A. 17-4 was to grant a personal gain or advantage to Defendants. The Supreme Court affirmed, holding that S.A. 17-4 provided an exclusive, private benefit to Defendants that no other similarly situated litigant could enjoy, in violation of the public emoluments clause. View "State v. Avoletta" on Justia Law

The Supreme Court held that absolute immunity attaches to statements made in judicial or quasi-judicial proceedings and that while Jane Doe was not entitled to absolute immunity, a qualified privilege is appropriate for alleged victims of sexual assault presented in the context of this case.In disciplinary proceedings conducted at Yale University by the University-Wide Committee on Sexual Misconduct (UWC) Doe accused Plaintiff of sexual assault, resulting in Plaintiff's expulsion from Yale and criminal charges being brought against him. Plaintiff was acquitted. At issue in this appeal was whether Doe, who enjoyed absolute immunity in a subsequent civil action challenging her testimony given during Plaintiff's criminal proceeding, should likewise be afforded absolute immunity from suit for her statements made during the UWC proceeding. The Supreme Court held (1) absolute immunity attaches to statements in judicial or quasi-judicial proceedings; (2) the USC's proceeding did not meet the conditions necessary to be considered quasi-judicial, and therefore, Doe was not entitled to absolute immunity; but (3) due to the public interest in encouraging the proper reporting of sexual assaults a qualified privilege is appropriate for alleged victims of sexual assault at institutions of higher education. View "Khan v. Yale University" on Justia Law

The Supreme Court dismissed this appeal stemming from the COVID-19 pandemic and the controversy over whether a mandate should be implemented requiring the state's schoolchildren to wear masks while in school, holding that this Court lacked jurisdiction.In June 2020, the state Department of Education, the state Commissioner of Education, and the Governor (collectively, Defendants) undertook to mandate that schoolchildren wear masks in school. Plaintiffs brought this lawsuit challenging the legality of Defendants' school mask mandate and seeking declaratory and injunctive relief. The Supreme Court granted summary judgment for Defendant, concluding that Plaintiffs were not entitled to relief. Plaintiffs appealed. The Supreme Court dismissed the appeal, holding that because the Department repealed the school mask mandate while this appeal was pending, the appeal was moot. View "Conn. Freedom Alliance, LLC v. Dep't of Education" on Justia Law

The Supreme Court affirmed the judgment of the trial court dismissing the appeal brought by the Board of Education of the City of New Haven after a human rights referee concluded that the Board had discriminated against a student on the basis of his disabilities and awarding damages of $25,000, holding that the Board was not entitled to relief on its claims of error.Specifically, the Supreme Court held (1) the trial court did not err in determining that the Commission on Human Rights and Opportunities had subject matter jurisdiction to adjudicate the student's claim that the Board had violated the Americans with Disabilities Act, 42 U.S.C. 12101 et seq.; (2) the trial court properly concluded that the Commission had subject matter jurisdiction over the student's claims when his father failed to exhaust his administrative remedies pursuant to the Individuals with Disabilities Education Act, 20 U.S.C. 1400 et seq.; and (3) the Board's third claim was not reviewable on appeal. View "Board of Education v. Commission on Human Rights & Opportunities" on Justia Law

The Supreme Court affirmed the judgment of the trial court denying certain defendants' motion to dismiss Plaintiffs' complaint, holding that Defendants were not entitled to sovereign immunity.Plaintiffs, the parents of four school-age children diagnosed with autism spectrum disorder, brought this action seeking judgment from the City of Norwalk's Board of Education and three of its members. Plaintiffs alleged that the negligent hiring and supervision of Stacy Lore, who was hired to provide autism related services to children in the school district, proximately caused them to suffer permanent and ongoing injuries and losses. The Board filed a motion to dismiss for lack of jurisdiction and, in the alternative, claiming that the doctrine of sovereign immunity mandated dismissal of the claims. The trial court granted the motion to dismiss on the ground that Plaintiffs had failed to exhaust their administrative remedies. The Supreme Court affirmed but on other grounds, holding (1) the trial court improperly dismissed this action on the ground that Plaintiffs had not exhausted their administrative remedies; and (2) the Board and its members were not entitled to sovereign immunity because they were acting under the control of, and as an agent of, the municipality rather than the state. View "Graham v. Friedlander" on Justia Law

The Supreme Court reversed the judgment of the Appellate Court reversing the judgment of the trial court after concluding that expert testimony was necessary to establish the standard of care in this negligence action, holding that, under the facts of this case, expert testimony was not necessary.Plaintiffs, a minor child, by and through her mother, alleged that the City of Waterbury and the Waterbury Board of Education were negligent for injuries sustained by the child during recess at a Waterbury public school. The trial court rendered judgment in favor of Plaintiffs. The Appellate Court reversed, concluding that the trial court improperly found in the absence of expert testimony that Defendants breached their duty of care to the child on the basis that there was an inadequate number of adults on the playground to supervise the students at the time the child was injured. The Supreme Court reversed, holding that the fact finder here did not need to apply scientific or specialized knowledge to determine whether Defendants adequately supervised the children in this case. View "Osborn v. Waterbury" on Justia Law

At issue was whether the trial court erred in determining that Plaintiff proved the imminent harm to identifiable persons exception to the defense of governmental immunity with respect to injuries he sustained when other students ran with a pair of scissors in the auditorium of his school.Plaintiff filed suit against the City of New Haven, the Board of Education of the City of New Haven, and the Superintendent of New Haven Public Schools seeking damages for, inter alia, negligent supervision of students. The trial court found in favor of Plaintiff on his negligent supervision claim. The Supreme Court reversed in part the judgment of the trial court, holding (1) Plaintiff failed to prove that Defendants’ conduct subjected an identifiable person to imminent harm; and (2) the trial court implicitly granted Defendants’ request to amend their answer to plead governmental immunity as a special defense. View "Martinez v. New Haven" on Justia Law

The trial court did not err in determining that Plaintiffs failed to establish that the state’s educational offerings are not minimally adequate under Conn. Const. art. VIII, 1.Plaintiffs brought this action seeking, inter alia, a declaratory judgment that various state officials and members of the State Board of Education failed to provide “suitable and substantially equal educational opportunities” in violation of Conn. Const. art. VIII, 1 and Conn. Const. art. I, 1 and 20, as amended by articles five and twenty-one of the amendments. The trial court concluded that the state’s educational policies and spending practices violate article eighth, section one and rejected Plaintiffs’ remaining arguments. The Supreme Court affirmed in part and reversed in part, holding that Plaintiffs failed to establish that Defendants violated Plaintiffs’ rights under article eighth, section one and article first, sections one and twenty. View "Connecticut Coalition for Justice in Education, Inc. v. Rell" on Justia Law

The parties in this case - a board of education and an education association - proceeded to arbitration on a dispute. The parties proceeded on a three member arbitration panel. When a journalist with a newspaper sought to cover the arbitration proceedings, the panel adjourned to what it designated an executive session, closed to the public. The journalist and newspaper (together, Defendants) filed a complaint with the Freedom of Information Commission, claiming that the panel violated the open meetings provision of the Freedom of Information Act (FOIA). The Commission ordered the members of the arbitration panel and the Department to create a transcript of the hearing and provide that transcript to Defendants, concluding that the arbitration panel was a committee of the Department of Education and that the evidentiary portion of the arbitration proceeding under the Teacher Negotiation Act (TNA) was subject to the open meetings provision of the FOIA. The Supreme Court reversed, holding that because a TNA arbitration panel is not a “committee of” the Department, it does not constitute a “public agency.” View "Gould v. Freedom of Info. Comm’n" on Justia Law

After a hearing, the Department of Children and Families substantiated allegations that Plaintiff, an elementary school teacher, emotionally abused one of his students and recommended that Plaintiff’s name be placed on the Department’s central registry of child abuse and neglect. The trial court affirmed, ruling that the ultimate finding of the administrative hearing officer was supported by substantial evidence. The Appellate Court reversed and ordered the Department to remove Plaintiff’s name from the central registry. The Supreme Court reversed, holding that the Appellate Court (1) failed properly to credit the factual findings and legal conclusions of the administrative hearing officer; and (2) improperly concluded that the definition of “abused” found in Conn. Gen. Stat. 46b-120(3) was void for vagueness as applied to the facts of this case. View "Frank v. Dep’t of Children & Families" on Justia Law