Justia Connecticut Supreme Court Opinion Summaries

Articles Posted in Injury Law
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Plaintiffs, the administrators of Decedent's estate, brought a medical malpractice action against Defendants, a thoracic surgeon and the surgeon's employer. Plaintiffs attached to their original complaint an opinion letter from a physician who was board certified in internal medicine with a subspecialty in cardiovascular disease. Plaintiffs subsequently filed an amended complaint. Defendants moved to dismiss Plaintiffs' original complaint on the grounds that Plaintiffs failed to comply with the requirements of filing a medical malpractice lawsuit mandated by Conn. Gen. Stat. 52-109a(a) as a result of their failure to attach to their complaint an opinion letter from a similar health care provider. The trial court granted the motion. The Supreme Court reversed, concluding that Defendants waived their right to challenge the sufficiency of the original complaint and its attachment by failing to timely file a motion to dismiss. Remanded. View "Morgan v. Hartford Hosp." on Justia Law

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Plaintiff, Metropolitan Property and Casualty Insurance Company, brought a product liability action against Defendant, Deere and Company, claiming that a lawn tractor manufactured by Defendant contained a manufacturing defect in its electrical system that caused a fire resulting in the destruction of the home of Plaintiff's insureds. Following a jury trial, the trial court rendered judgment in favor of Plaintiff. The Supreme Court reversed, holding (1) a plaintiff may base a product liability action on the "malfunction theory," which allows a jury to rely on circumstantial evidence to infer that a product that malfunctioned was defective at the time it left the manufacturer's or seller's control if the plaintiff establishes certain elements; and (2) the trial court erred in denying Defendant's motion for a directed verdict because Plaintiff's evidence in the present case was insufficient to establish its products liability claim. View "Metro. Prop. & Cas. Ins. Co. v. Deere & Co." on Justia Law

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Plaintiffs, John and Colm Farrell, were allegedly involved in a motor vehicle accident with an insured of Defendant, Twenty-First Century Insurance Company. Plaintiffs filed an action against Defendant, seeking damages for personal injuries arising out of the accident. During a pretrial conference, the parties agreed to settle Plaintiffs' claims and, allegedly, further agreed to arbitrate Plaintiffs' claims. Subsequently, Plaintiffs filed an action against Defendant seeking a court order to compel arbitration. The trial court rendered summary judgment in favor of Defendant, concluding that there was no clear manifestation of an agreement to arbitrate. The appellate court affirmed. The Supreme Court affirmed the judgment of the appellate court, holding that, after drawing all inferences in favor of Plaintiffs, no genuine issue of material fact existed with regard to whether the parties had an enforceable agreement to arbitrate. View "Farrell v. Twenty-First Century Ins. Co." on Justia Law

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Plaintiff, employee, brought an action against Defendants, an archdiocese and a parish pastor, claiming that their refusal to renew her contract for employment as the principal of the parish school constituted, inter alia, wrongful termination in violation of public policy, breach of implied contract and breach of promissory estoppel. The trial court denied Defendants' motion to dismiss the action on the ground that adjudication of Plaintiff's claims called for impermissible judicial interference in the internal governance of the archdiocese with respect to its selection of religious leaders. At issue on appeal was whether the ministerial exception to judicial authority that precludes a court from adjudicating certain religious disputes required dismissal of the action. The Supreme Court first determined it had subject matter jurisdiction over the interlocutory appeal, and then reversed the trial court, holding that (1) in considering whether the ministerial exception is applicable in a particular case, a Connecticut state court must follow the Rweyemamu v. Cote standard; and (2) the ministerial exception applied to the various claims in the plaintiff's complaint. Remanded with direction to dismiss Plaintiff's complaint. View "Dayner v. Archdiocese of Hartford" on Justia Law

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Employee was diagnosed with silicosis, a condition caused by work with Employer, and filed a claim for workers' compensation benefits. During the course of Employee's employment, Employer's workers' compensation liability was covered by two insurers, first Liberty Mutual and, later, American Mutual. After Employee terminated his employment, American Mutual was declared insolvent. The Connecticut Guarantee Association subsequently became liable for certain American Mutual obligations. The workers' compensation commissioner held the association initially liable for payment of benefits as the last insurer on the risk. The workers' compensation review board affirmed. The association appealed, contending that deeming the association liable conflicted with the requirement under the Connecticut Insurance Guaranty Association Act that other insurance policies covering the same claim must be exhausted before recovery is permitted from the association. The Supreme Court affirmed, concluding that holding the association liable for an insolvent insurer's obligation as the last insurer on the risk does not conflict with the Guaranty Act. View "Franklin v. Superior Casting" on Justia Law

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In 2000, the manager of the Goodspeed Airport cut down trees and woody vegetation on property owned by a land trust. A total of six actions were filed as a result of the clear-cutting. In addition to instituting two of three consolidated actions, the airport brought two federal actions, and the district court found in favor of the land trust in both actions. In state court three other actions were consolidated. The trial court concluded that (1) the airport parties' claims for substantive and procedural due process were barred by the doctrine of res judicata, and (2) the airport parties' claims claims for first amendment retaliation and abuse of process were barred by the doctrine of collateral estoppel. The Supreme Court affirmed, holding that either the issues were actually litigated in the federal actions and thus are barred by collateral estoppel, or the claims could have been raised in the federal actions and thus are barred by res judicata. View "Ventres v. Goodspeed Airport, L.L.C." on Justia Law

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Plaintiffs sued defendants, the board of education of the town of Watertown ("board"), the town of Watertown ("town"), and two teachers employed by the board, claiming that, as a result of defendants' negligence, one plaintiff severely injured her foot at a school dance sponsored by the board. At issue was whether the trial court improperly granted defendants' motion to strike the claims on the grounds that negligence claims against the town and board were barred by the doctrine of governmental immunity and did not come within the scope of the statutory waiver of government immunity set forth in General Statutes 52-557n; that the claims against the two teachers were barred because section 52-557n did not create a cause of action against individual municipal employees; and that, in the absence of a common law negligence claim against the teachers, there was no basis for an indemnification claim pursuant to General Statutes 7-465. The court held that the trial court properly granted defendants' motion to strike count one as to the town and the board because they were immune from suit pursuant to 52-557n(a)(2)(B) and properly determined that section 52-557n did not authorize suit against individual government employees. The court also held that the trial court improperly granted the motion to strike the first count of the complaint as to the two teachers and the entire second count seeking payment from the town and the board pursuant to section 7-465 on the ground that plaintiffs had not alleged common law negligence against the teachers. The court further held that the trial court's ruling could be affirmed on the alternate ground that the teachers were immune from liability under the doctrine of qualified immunity. Accordingly, the judgment was affirmed.

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Plaintiff Randall Motzer worked for Defendants Edward Haberli and E. Haberli Electric, LLC as an electricianâs apprentice. In June, 2004, he was working on a job site to help install electrical wiring through the ground floor of an apartment complex. The task required two people to complete. Bryan Papillo, the other worker, drilled holes through the floor above and fed wires to Plaintiff working below. In one instance, Plaintiff put his fingers through the hole to retrieve the wires and heard Papillo yell something just as a drill bit came down on Plaintiffâs finger. Plaintiff had to have part of his finger removed. As a result of this injury, Plaintiff received workersâ compensation benefits. Notwithstanding the benefits, Plaintiff filed a two count complaint against Defendants, alleging among other things, Defendants engaged in âserious and willful misconductâ and that conduct lead to Plaintiffâs injury. Defendants denied responsibility and raised five special defenses. A jury trial on the matter began in March, 2009. At the close of the case, Defendants moved for a directed verdict alleging Plaintiff failed to prove Defendants were the cause of Plaintiffâs injury. The trial court rendered judgment for Defendants. On review, the Supreme Court found that the record was sufficient to support the trial courtâs grant of a directed verdict to Defendants. The Supreme Court affirmed the judgment of the trial court.