Justia Connecticut Supreme Court Opinion Summaries

Articles Posted in Government & Administrative Law
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The Supreme Court reversed the appellate court's judgment reversing in part the decision of the Town Plan and Zoning Commission of the Town of Fairfield extending its approvals of a special permit and a coastal site plan review granted to Fairfield Commons, LLC, holding that a local zoning authority may not, by regulation, condition the continuing validity of a special permit on completing development in connection with the permitted use within a period of time that is shorter than the statutory period.The appellate court in this case affirmed the trial court's judgment concluding that the Commission improperly granted Fairfield Commons' request for an extension of its special permit deadline to complete development but reversed the court's conclusion that the special permit could not be subject to a temporal limitation as a matter of law. The Supreme Court reversed, holding (1) a special permit regulation may not prescribe a shorter time limitation for completing development than the statutory period set forth for completion of development in connection with an accompanying site plan under Conn. Gen. Stat. 8-3(i) and (m); and (2) the appellate court incorrectly concluded that the special permit at issue expired in April 2011. View "International Investors v. Town Plan & Zoning Commission" on Justia Law

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The Supreme Court affirmed in part the judgment of the trial court dismissing in part and denying in part Defendant's two motions to correct an illegal sentence, one filed in each of his two criminal cases, holding that the trial court erred in part.Defendant was convicted in two separate cases for crimes he committed when he was fifteen years old. The trial court dismissed in part and denied in part Defendant's two motions to correct an illegal sentence, concluding that it lacked jurisdiction over Defendant's claims to correct, and that Defendant was not entitled to relief on his claim that his parole eligibility date, as calculated by the Board of Pardons and Parole, violated the terms of his plea agreement. The Supreme Court vacated in part, holding (1) the trial court should have denied, rather than dismissed, Defendant's claims that he was entitled to resentencing pursuant to Miller v. Alabama, 567 U.S. 460 (2012); and (2) the form of the judgment was improper insofar as the trial court denied Defendant's claim that his new parole eligibility date violated the terms of his plea agreement. View "State v. Myers" on Justia Law

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The Supreme Court reversed the judgment of the trial court sustaining Plaintiff's appeal from the decision of the Board of Representatives of the City of Stamford rejecting a zoning amendment approved by the Zoning Board of the City of Stamford, holding that the board of representatives did not have the authority to determine the validity of the petition.Local property owners filed a protest petition opposing the amendment. After determining that the protest petition was valid, the board of representatives considered and rejected the amendment. The trial court sustained Plaintiff's appeal, concluding that the board of representatives did not have the authority to consider whether the petition was valid. The Supreme Court reversed, holding (1) the trial court did not err in concluding that the board of representatives did not have the authority to determine the validity of the protest petition; but (2) the petition was valid because it contained the requisite number of signatures. View "High Ridge Real Estate Owner, LLC v. Board of Representatives" on Justia Law

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The Supreme Court affirmed the judgment of the trial court sustaining Plaintiffs' appeal from a determination of the Board of Representatives of the City of Stamford approving a protest petition that objected to master plan amendments approved by the Planning Board of the City of Stamford, holding that there was no error.Plaintiffs filed an application with the planning board to amend the City of Stamford's master plan. The planning board subsequently filed its own application to amend the city's master plan. The planning board approved both applications with some modifications. After local property owners filed a protest petition the board of representatives determined that the petition was valid and rejected the planning board's approval of the amendments. The trial court sustained Plaintiffs' appeal, holding that even if the board of representatives had the authority to vote on the validity of the protest petition, the vote was not sufficient. The Supreme Court affirmed, holding that the protest petition was invalid as to Plaintiffs' proposed amendment. View "Strand/BRC Group, LLC v. Board of Representatives" on Justia Law

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The Supreme Court affirmed the judgment of the trial court dismissing Plaintiff's appeal from the decision of the Commissioner of Banking revoking Plaintiff's license to serve as a mortgage lender in the state, holding that the Commissioner had the legal authority to suspend and revoke Plaintiff's mortgage lender license.Plaintiff filed an administrative appeal from the Commissioner's decision to revoke Plaintiff's mortgage lender license, arguing that the governing statutory scheme precluded the Department of Banking from suspending its license. The trial court affirmed the Commissioner's decision. The Supreme Court affirmed, holding that the trial court properly affirmed the Commissioner's decision. View "1st Alliance Lending, LLC v. Department of Banking" on Justia Law

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The Supreme Court affirmed the judgment of the trial court dismissing Appellants' administrative appeal from a declaratory ruling of the Connecticut State Employees Retirement Commission, holding that the trial court properly upheld the Commission's interpretation of various provisions of the State Employees Retirement Act, Mass. Gen. Stat. 5-152 et seq.Plaintiffs, former state employees, argued that the Commission improperly issued a declaratory ruling that, under various provisions of the Act, disability retirement benefit payments commence on the first day of the month following the Retirement Services Division's receipt of the employee's approved application for such benefits. The Supreme Court affirmed the judgment of the trial court upholding the Commission's decision, holding (1) the trial court properly gave substantial deference to the Commission's position that disability retirement benefits become payable on the first day of the month after the application is received; and (2) Plaintiffs failed to prove their second claim. View "Crandle v. Connecticut State Employees Retirement Commission" on Justia Law

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The Supreme Court affirmed the judgment of the trial court dismissing Appellants' appeal from the decision of the Planning and Zoning Commission of the City of Shelton approving an application for a planned development district submitted by Shelter Ridge Associates, LLC, holding that the trial court did not err or abuse its discretion.Specifically, the Supreme Court held (1) contrary to Appellants' argument on appeal, the zoning authority conferred by Conn. Gen. Stat. 8-2 supports the creation of planned development districts; (2) the planned development district proposed by Shelter Ridge did not violate the uniformity requirement contained in section 8-2; and (3) the Commission’s decision did not result in an unlawful subdivision. View "Tillman v. Planning & Zoning Commission of the City of Shelton" on Justia Law

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The Supreme Court affirmed the judgment of the trial court dismissing Plaintiff's administrative appeal from the decision of the Connecticut Siting Council approving the application of NTE Connecticut, LLC (NTE) seeking a certificate of environmental compatibility and public need for the construction of an electric generating facility in the town of Killingly, holding that there was no error.Plaintiff, a nonprofit organization, appealed the council's decision to the trial court, arguing that the council improperly refused to consider the environmental impact of installing a gas pipeline to its proposed facility when weighing the public benefit of the facility against its probable environmental impact. The trial court dismissed the appeal, concluding that the council was not required to consider the impact of the gas pipeline. The Supreme Court affirmed, holding that the trial court correctly determined that the council’s refusal to consider the potential environmental impact of the gas pipeline during the proceedings on NTE’s application for a certificate was not arbitrary or capricious. View "Not Another Power Plant v. Connecticut Siting Council" on Justia Law

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The Supreme Court overruled Savage v. St. Aeden’s Church, 189 A. 599 (Conn. 1937), insofar as it concluded that an employee is entitled to compensation as a matter of law when, during the course of the employee's employment, he or she is injured due to an idiopathic fall onto a level floor.The Appellate Court reversed the decision of the Compensation Review Board (Board) affirming the decision of the Workers' Compensation Commissioner for the Second District (Commissioner) denying Plaintiff's application for benefits filed after she suffered a syncopal episode at her workplace, which caused her to fall backward and strike her head on the ground, concluding that, under Savage, Plaintiff's injury was compensable as a matter of law. The Supreme Court reversed after overruling the portion of Savage at issue, holding that the risk or condition must be "peculiar to the employment" for the injury to be compensable. View "Clements v. Aramark Corp." on Justia Law

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The Supreme Court reversed the judgment of the appellate court affirming the judgments of the trial court dismissing Plaintiff's appeals challenging various text amendments to the Hartford Zoning Regulations and zoning map changes made by the City of Hartford's Planning and Zoning Commission, holding that the appellate court erred.Plaintiff applied for a special permit to construct a restaurant on property that it owned in the City. Thereafter, Plaintiff filed four separate appeals challenging the City's zoning map changes which, if properly adopted, would effectively preclude Plaintiff from obtaining the special permit. The trial court dismissed the appeal on the ground that Plaintiff had failed to exhaust its administrative remedies. The appellate court affirmed. The Supreme Court reversed, holding (1) the appellate court erred in determining that the City's zoning administrator had the authority to void Plaintiff's application for a special permit; and (2) Plaintiff could not have appealed the zoning administrator's action to the zoning board of appeals because it was not a legal decision for purposes of Conn. Gen. Stat. 8-6. View "Farmington-Girard, LLC v. Planning & Zoning Commission of City of Hartford" on Justia Law