Justia Connecticut Supreme Court Opinion Summaries

The plaintiff sought to register as a write-in candidate for the United States representative for the Third Congressional District of Connecticut in the November 2024 election. She claimed her registration was untimely due to following outdated guidance from the defendant, the Secretary of the State, which quoted an old version of the statute governing write-in candidacies. The plaintiff requested an order directing the defendant to accept her registration.The Superior Court previously dismissed the plaintiff's attempts to obtain relief for lack of jurisdiction. The plaintiff then brought this action under General Statutes § 9-323, seeking an emergency hearing to challenge the defendant's decision.The Connecticut Supreme Court held that the case was not moot despite being heard after election day, as practical relief was still available. The court found that the plaintiff was aggrieved by the defendant's ruling, as the untimely filing was allegedly due to erroneous information provided by the defendant's office.Assuming without deciding that courts have the authority to excuse noncompliance with mandatory filing deadlines due to election official actions, the court concluded that the plaintiff was not entitled to relief under the doctrine of equitable estoppel. The court noted that the correct deadline was clearly stated in both the cover letter and the registration form, and the plaintiff failed to exercise due diligence in resolving the apparent discrepancy.The court denied the plaintiff's request for an injunction and rendered judgment for the defendant, holding that the plaintiff's lack of due diligence did not warrant equitable relief from the mandatory statutory deadline. View "Whitnum Baker v. Secretary of the State" on Justia Law

Three registered electors from Bridgeport filed a writ of error challenging a trial judge's decision to deny their applications for arrest warrants for two individuals who allegedly violated election laws during the 2023 Democratic primary for the mayoral office. The plaintiffs claimed that the trial judge misinterpreted the relevant statute, General Statutes § 9-368, which they argued mandated the issuance of arrest warrants upon their complaint. The state of Connecticut, the defendant in error, argued that the writ should be dismissed because the plaintiffs were neither statutorily nor classically aggrieved by the denial of their applications.The Superior Court for the judicial district of Fairfield, with Judge Thomas J. Welch presiding, denied the applications for arrest warrants. The judge concluded that § 9-368 was inconsistent with the federal and state constitutions and the rules of practice, as it allowed for the issuance of arrest warrants based on a standard less than probable cause and without coordination with the Division of Criminal Justice. The judge did not reach the substantive merits of the applications and suggested that the matter could be referred to a prosecuting authority.The Supreme Court of Connecticut reviewed the case. The court held that the plaintiffs in error were not required to establish statutory aggrievement to bring a writ of error. However, the court dismissed the writ on the grounds that the plaintiffs were not classically aggrieved. The court determined that the plaintiffs lacked a specific, personal, and legal interest in the arrest and prosecution of those who allegedly violated election laws, as they were private citizens without a judicially cognizable interest in the prosecution or nonprosecution of another. Consequently, the plaintiffs did not have standing to challenge the trial judge's denial of their arrest warrant applications. View "In re Criminal Complaint & Application for Arrest Warrant" on Justia Law

The case involves two competing slates of candidates seeking to appear on the ballot for the March 5, 2024, primary election for the Democratic Town Committee for the seventh district of Hartford. The plaintiffs, members of one slate, challenged the validity of a petition sheet submitted by the defendants, members of the other slate, on the grounds that one signature was not signed by the named individual but by his son under a purported power of attorney. The defendants counterclaimed, arguing that five petition sheets submitted by the plaintiffs should be invalidated for not including a written tally of the number of verified signatures as required by statute.The Superior Court in the judicial district of Hartford found that the signature in question on the defendants' petition sheet was invalid because there was no evidence that the son had a valid power of attorney or that it included the authority to sign political petitions. Consequently, the court rejected the entire petition sheet, reducing the defendants' valid signatures below the required threshold, and ordered their removal from the ballot. The court also found that one of the plaintiffs' petition sheets contained a forged signature and rejected it, but it ruled that the other five challenged sheets substantially complied with the statutory requirements despite lacking the signature tally.The Connecticut Supreme Court reviewed the case and agreed with the trial court that the signature on the defendants' petition sheet was invalid and that the entire sheet must be rejected. The court held that the statutory language was clear in requiring the rejection of any petition page with procedural violations, including false attestations. However, the Supreme Court disagreed with the trial court's finding of substantial compliance for the plaintiffs' five petition sheets lacking the required tally. The court held that these sheets must also be rejected, which would reduce the plaintiffs' valid signatures below the required threshold, disqualifying both slates from the primary ballot.The judgment was reversed in part and affirmed in part, with the case remanded for further proceedings to determine the conduct of the primary election with both slates disqualified. View "Airey v. Feliciano" on Justia Law

In this case, two candidates for state legislative offices in the 2014 general election, Joe Markley and Rob Sampson, were fined by the State Elections Enforcement Commission for violating state statutes and regulations governing campaign financing. The candidates' campaign committees had received public funding grants and published communications that criticized the then-governor, who was running for reelection. The commission found that the candidates had violated the applicable statutes and regulations by using their campaign funds to pay for communications that criticized the governor while promoting their opposition to his policies.The candidates appealed to the trial court, arguing that the statutes and regulations violated their First Amendment rights by restricting their ability to speak about other, non-opposing candidates. The trial court upheld the commission's decision, agreeing that the candidates had violated the statutes and regulations and concluding that the restrictions did not infringe on the candidates' First Amendment rights.On appeal to the Supreme Court of Connecticut, the candidates argued that the commission's enforcement of the statutes and regulations violated their First Amendment rights. The court held that the commission's enforcement of the statutes and regulations imposed an unconstitutional condition in violation of the First Amendment. The court found that the commission's enforcement of the statutes and regulations penalized the candidates for mentioning the governor's name in a manner that was not the functional equivalent of speech squarely directed at his reelection campaign. The court reversed the trial court's judgment and remanded the case with direction to sustain the candidates' administrative appeal. View "Markley v. State Elections Enforcement Commission" on Justia Law

In the dispute over two slates of candidates each purporting to be the endorsed slate of the Independent Party of Danbury for various municipal offices in the city of Danbury, the Connecticut Supreme Court held that a town clerk has a ministerial obligation to accept and file with the Secretary of State's office lists of minor party candidates that are facially valid under the terms of the state statute. The court found that the town clerk exceeded her authority by failing to file a slate of candidates approved at an Independent Party meeting, and the court should have ordered the clerk to forward that slate to the Secretary of State's office. However, the court also held that the town clerk properly filed a slate of candidates approved at a different Independent Party meeting because the submission of that slate complied with the certification requirement of the state statute. The court concluded that, given the ministerial role of the town clerk, she had no choice but to accept and transmit to the secretary both filings purporting to be the endorsements of the Independent Party, since both were facially compliant with the governing statutes. The court affirmed the trial court's judgment that neither set of endorsements should be placed on the ballot. View "Alves v. Giegler" on Justia Law

In this case concerning various statutory provisions governing the absentee ballot process the Supreme Court affirmed the ruling of the trial court denying Plaintiff's action pursuant to Conn. Gen. Stat. 9-328 against the Democratic mayoral candidate for the city of West Haven and certain city election officials challenging the results of the mayoral election, holding that the trial court did not err in denying relief.Plaintiff brought this action arguing that various city election officials failed adequately to comply with the statutory requirements regarding absentee ballots. The trial court denied relief, holding that Plaintiff met his burden of proving that the election officials failed to strictly comply with certain statutory requirements but that the reliability of the election's result was not seriously in doubt. The Supreme Court affirmed, holding that Plaintiff failed to satisfy his burden of proving by a preponderance of the evidence that the reliability of the election's results was seriously in doubt, and therefore, the trial court properly denied Plaintiff's requested relief. View "Cohen v. Rossi" on Justia Law

The Supreme Court affirmed the judgment of the trial court rendered in favor of Defendants, various city election officials and the secretary of state, in this election contest, holding that Plaintiff's arguments on appeal were unavailing.Plaintiff claimed that she ran in the November 2020 election to fill a vacancy on the Board of Education of the City of Stamford, that she won the election, and that the City's election officials improperly refused to credit the election results on the ground that the Stamford Charter provides that the charter provides that the election to fill the vacancy could not be held until the "next biennial election" in 2021. The trial court entered judgment for Defendants. The Supreme Court affirmed, holding (1) this Court refuses to construe the phrase "next biennial election" to mean "next city election"; and (2) a charter provision limiting vacancy elections to odd-numbered years did not violate the First Amendment and that the City's failure to validate the votes at issue did not disenfranchise Plaintiff. View "O'Shea v. Scherban" on Justia Law

The Supreme Court reversed the judgment of the trial court dismissing Plaintiffs' administrative appeal for lack of subject matter jurisdiction from the adverse decision of the State Elections Enforcement Commission determining that Plaintiffs violated certain state election laws and regulations, holding that the administrative appeal was timely filed.In its decision, the Commission found that Plaintiffs, who had received funding for their campaigns through the Citizens' Election Program, had violated laws and regulations related to the Program and imposed civil fines for those violations. Plaintiffs appealed. The superior court dismissed the appeal on the ground that it was untimely filed under Conn. Gen. Stat. 4-183(c)(2). The Supreme Court reversed, holding (1) the timeliness of Plaintiffs' appeal was governed by the limitation period of Conn. Gen. Stat. 4-183(c)(3); and (2) Plaintiffs' appeal was timely filed under section 4-183(c)(3). View "Markley v. State Elections Enforcement Commission" on Justia Law

The Supreme Court affirmed the judgment of the trial court in favor of Defendant, Denise Merrill, Secretary of the State, intros action seeking declaratory and injunctive relief with respect to Defendant's change of the absentee ballot application for the August 11, 2020 primary election to add COVID-19 as a new reason for requesting an absentee ballot pursuant to Executive Order No. 7QQ, holding that the trial court did not err.At issue in this public interest appeal was whether Governor Ned Lamont's executive order, which was later ratified by the legislature and which modified Conn. Gen. Stat. 9-135 by adding COVID-19 as a permissible reason for absentee voting violates Conn. Const. art. VI, 7. The trial court granted jumtgnet for Defendant. The Supreme Court affirmed, holding that Executive Order No. 7QQ does not violate Article 6, Section 7. View "Fay v. Merrill" on Justia Law

The Supreme Court granted Defendant's motion to dismiss this action claiming seeking declaratory and injunctive relief challenging the Secretary of State's (Defendant) "ruling of an election official," which added a seventh category for absentee voting, "COVID-19," to the application for absentee ballots for the August 11, 2020 primary election in contemplation of the ongoing pandemic, holding that this Court lacked subject matter jurisdiction.Plaintiffs, four candidates in the August primary for the Republican Party's nomination for the office of United States representative for Connecticut's First and Second Congressional Districts, brought this proceeding pursuant to Conn. Gen. Stat. 9-323, claiming that Defendant's change to the application violated Conn. Const. art. VI, 7 and that the application was inconsistent with the terms of Executive Order No. 7QQ. Defendant moved to dismiss the complaint for lack of subject matter jurisdiction. The Supreme Court granted the motion to dismiss, holding that jurisdiction lay in the Superior Court in the judicial district of Hartford. View "Fay v. Merrill" on Justia Law