Justia Connecticut Supreme Court Opinion Summaries

In 2003, local districts established for the promotion of tourism were legislatively dissolved to make way for larger regional districts serving that same purpose. Plaintiff, a Massachusetts corporation, filed suit against one of the regional districts (Defendant) seeking to hold Defendant liable for damages under a contract that Plaintiff had executed with one of the local districts (Local District). The district court certified questions of law to the Supreme Court regarding the satisfaction of contingent liabilities of the legislatively dissolved local districts. The Supreme Court answered (1) Defendant is not the legal successor to the Local District, as the legislature did not intend to make the regional districts the legal successors to the local districts; and (2) if the Local District transferred any of its assets to another entity and Plaintiff can establish that the assets were fraudulently conveyed, that entity may be responsible for the Local District’s obligations to the extent of the value of the assets received. View "Single Source, Inc. v. Cent. Reg’l Tourism Dist., Inc." on Justia Law

At issue in this certified appeal was the extent of a law enforcement agency’s disclosure obligations under the Freedom of Information Act (Act) with respect to pending criminal investigations. In 1993, the Supreme Court decided Gifford v. Freedom of Information Commission, which held that the police’s disclosure obligations during a pending criminal investigation were governed by the statutory predecessor to Conn. Gen. Stat. 1-215, which required a law enforcement agency to release only police blotter information. The legislature subsequently enacted Public Acts 1994, No. 94-246, 13, which amended the statutory predecessor to section 1-215 to require broader disclosure. In the instant case, the Freedom of Information Commission (Commission) found that the Department of Public Safety (Department) violated the Act by failing to disclose certain records from a pending criminal case. The trial court sustained the Department’s administrative appeal, and the Appellate Court affirmed. The Supreme Court affirmed, holding the enactment of Public Act 94-246 did not legislatively overrule the Court’s conclusion in Gifford that, during pending criminal prosecutions, section 1-215 exclusively governs law enforcement agencies’ disclosure obligations under the Act. View "Comm’r of Pub. Safety 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

Plaintiffs, two unions, filed a petition for a declaratory ruling with the Department of Public Utility Control seeking a ruling establishing that the Department had violated the Uniform Administrative Procedure Act by failing to promulgate regulations prescribing the rights of persons designated as participants in uncontested proceedings before the Department. The Department denied Plaintiffs’ petition. The trial court set aside the Department’s decision, concluding that the Department was required to promulgate the regulations. The Supreme Court reversed, holding that the trial court lacked jurisdiction over Plaintiffs’ appeal because Plaintiffs did not plead sufficient facts that, if true, demonstated that they were aggrieved by the Department’s ruling on their petition. Remanded with direction to dismiss Plaintiffs’ appeal. View "Conn. Indep. Util. Workers, Local 12924 v. Dep’t of Pub. Util. Control" on Justia Law

While working for Employer, Employee filed notice of a workers' compensation claim related to a lower back injury he received during the course of his employment. Employee was discharged approximately four years later pursuant to a termination agreement that provided that he agreed to release Employer from any and all workers' compensation claims. Employer later brought an action against Employee, alleging civil theft, fraud, unjust enrichment, and conversion based on Defendant's admission that he never intended to release his workers' compensation claim. Employee counterclaimed, claiming that Employer's cause of action was in retaliation for Employee's decision to exercise his rights under the Workers' Compensation Act. Employer filed a motion to dismiss the counterclaim, asserting that the doctrine of absolute immunity shielded Employer from the counterclaim. The trial court denied the motion. The Supreme Court affirmed the trial court's decision denying Plaintiff's motion to dismiss, holding that an employer's right to seek redress for its alleged grievances in court does not outweigh an employee's interest in exercising his rights under the Act without fear of retaliation by his employer, and therefore, absolute immunity did not shield Employer from Employee's counterclaim.View "MacDermid, Inc. v. Leonetti" on Justia Law

Plaintiff’s spouse (Spouse) applied to the Commissioner of Social Services (Department) for Medicaid benefits. After a review of the combined assets of both Spouse and Plaintiff, the Department concluded that Spouse was not eligible to receive Medicaid benefits. A hearing officer denied Plaintiff’s appeal, as did the superior court. The Supreme Court affirmed, holding that the trial court correctly concluded that the Department did not act arbitrarily or abuse its discretion in finding that the Department applied the correct eligibility and availability of assets criteria when evaluating the application for Medicaid benefits submitted by Spouse. View "Palomba-Bourke v. Comm’r of Soc. Servs." on Justia Law

Defendant was selected by the City of Bridgeport Board of Education to serve as its acting superintendent of schools. Because Defendant was not certified as a school superintendent in Connecticut, Defendant completed an independent study course, and the Commissioner of Education granted a waiver of certification for Defendant pursuant to Conn. Gen. Stat. 10-157(b). Plaintiffs sought a writ of quo warranto that would remove Defendant from his office as acting superintendent. The trial court rendered judgment in favor of Plaintiffs, concluding that because Defendant did not complete a school leadership program required by section 10-157(b), he was not entitled to a waiver of certification. Defendant appealed. The Supreme Court reversed, holding that a quo warranto action may not be utilized to avoid that administrative process by mounting a collateral attack on an administrative agency's decision to issue a waiver that renders a public officer qualified to hold his position. Remanded.View "Lopez v. Bd. of Educ." on Justia Law

Complainants, an attorney and the Office of the Chief Public Defender, submitted a request for a declaratory ruling to the Connecticut Medical Examining Board asking whether physician participation in the execution of condemned inmates using lethal injection was permitted. Complainants then sent a letter regarding their request for a declaratory ruling. The Board convened an executive session to obtain legal advice about issues raised in the letter. Complainants then filed a complaint with the Commission, alleging that Plaintiffs, the Board and its chairperson, violated the Freedom of Information Act by convening in executive session during the meeting for "purposes not permitted" under the Act. The Commission determined the executive session was impermissible under the Act. The trial court upheld the Commission's decision. The Supreme Court affirmed, holding that the letter did not constitute notice of a pending claim as defined by Conn. Gen. Stat. 1-200, and therefore, the Board was not permitted to convene in executive session under the Act. View "Chairperson, Conn. Med. Examining Bd. v. Freedom of Info. Comm'n" on Justia Law

The Town of Malborough terminated the employment of Emily Chaponis as town assessor after the board of selectmen did not make a motion to reappoint her to a successive term of office. Chaponis filed a grievance through the Union, of which she was a member, alleging that the Town violated its collective bargaining agreement with the Union by discharging her without just cause. An arbitration panel ordered the Town to reinstate Chaponis to her position, concluding that the Town violated the agreement when it terminated Chaponis' employment without just cause. The trial court denied the Town's application to vacate the arbitration award. The Supreme Court reversed, holding that the arbitrators' award ordering the reinstatement of Chaponis' employment after the statutory expiration of her term of office contravened the mandates of the statutory scheme governing the term of office for municipal officers, and therefore, the award was unenforceable. Remanded. View "Town of Marlborough v. AFSCME, Council 4, Local 818-052" on Justia Law

Plaintiff, a licensed physician and surgeon, was charged with violating the applicable standard of care in his treatment of two children. The Connecticut Medical Examining Board (board) found that Plaintiff had violated the standard of care with respect to his treatment of both children and ordered a reprimand, imposed fines, and placed Plaintiff on probation for two years. The trial court primarily affirmed, as did the appellate court. Plaintiff appealed, asserting that the appellate court incorrectly concluded that the preponderance of the evidence standard applied in his disciplinary hearing rather than the clear and convincing evidence standard. The Supreme Court affirmed, holding (1) the preponderance of the evidence standard applied at the proceeding because the board is an administrative agency subject to the Uniform Administrative Procedure Act, under which the preponderance of the evidence is the default standard of proof; and (2) the use of the preponderance of the evidence standard of proof at a physician disciplinary proceeding does not offend a physician's due process rights. View "Jones v. Conn. Med. Examining Bd." on Justia Law