Justia Connecticut Supreme Court Opinion Summaries

Plaintiff's newborn son died shortly after Plaintiff gave birth. Plaintiff, as administratrix of the estate of her son, later brought a medical malpractice action against her obstetrician and nurse midwife and their employer ("Hospital"). Because Hospital was sold to Defendants nine months after the events leading to the present action, Plaintiff also sued Defendants under a theory of successor liability. After reaching a settlement and executing two covenants not to sue, Plaintiff withdrew her claims against Hospital and its employees. The trial court granted summary judgment for Defendants, concluding that the covenant not to sue Hospital prevented Plaintiff from seeking to recover from Defendants. The Appellate Court reversed. The Supreme Court reversed the Appellate Court, holding that Plaintiff’s execution of the covenant not to sue Hospital in perpetuity foreclosed, as a matter of law, her right of action against Hospital and against any subsequent purchaser of Hospital’s assets under the mere continuation theory of successor liability. View "Robbins v. Physicians for Women's Health, LLC" on Justia Law

Plaintiff filed for a divorce from Orang Fabriz, with whom she had a daughter. Defendant was hired to supervise visits between Fabriz and the child. During a visit supervised by Defendant at a shopping mall, Fabriz abducted the child and took her with him to Istanbul, Turkey. Plaintiff subsequently filed this negligence action against Defendant. The trial court found in favor of Defendant. The appellate court reversed and remanded for a new trial, concluding that the trial court engaged in a flawed analysis of causation and foreseeability and that the court made two clearly erroneous factual findings. The Supreme Court affirmed, holding that the appellate court correctly found the trial court's foreseeability analysis was fundamentally flawed. View "Mirjavadi v. Vakilzadeh" on Justia Law

This case arose from disputes between the Department of Information Technology and Defendant, a computer equipment supplier, over two contracts between the parties. The Department filed this action against Defendant, alleging breach of contract and fraud claims. Defendant filed an amended counterclaim, alleging takings and due process violations. The Department moved to dismiss the takings and due process claims based on the State's sovereign immunity. The trial court determined that the Department had waived the State's sovereign immunity regarding Defendant's counterclaims by bringing this cause of action against Defendant. After a jury trial, the trial court awarded Defendant damages on its procedural due process counterclaim. The Supreme Court (1) reversed the judgment of the trial court in favor of Defendant on the procedural due process counterclaim, holding that the Department did not waive the state's sovereign immunity by initiating the present litigation, and therefore, the trial court lacked subject matter jurisdiction over Defendant's counterclaims; and (2) affirmed in all other respects. View "Chief Info. Officer v. Computers Plus Ctr., Inc." on Justia Law

Plaintiffs brought two separate actions alleging that Hazel Smart died as a result of a defective catheter used in her dialysis treatment at Greater Waterbury Gambro HealthCare. The trial court consolidated the two actions, which brought claims sounding in negligence, medical malpractice, loss of consortium, and products liability. During pretrial proceedings, the trial court imposed monetary sanctions on Plaintiffs for failure to comply with a discovery order. Plaintiffs appealed. The appellate court dismissed the appeal for lack of subject matter jurisdiction, finding that the trial court's discovery order was not an appealable final judgment. The Supreme Court affirmed, holding that the appellate court properly dismissed the appeal, as the trial court's order did not constitute an appealable final judgment. View "Incardona v. Roer" on Justia Law

Decedent admitted herself to Hospital for treatment for major depression and personality disorder. At the time of her admission, Decedent was diagnosed with high suicide ideation and had previously attempted suicide. One week later, Decedent committed suicide at Hospital. Plaintiff, the executor of Decedent's estate, filed a medical malpractice action against Hospital and Decedent's treating psychiatrist. The jury returned a verdict in favor of Defendants. The appellate court remanded the case for a new trial, concluding that the trial court improperly declined to the poll the jury to determine whether any of the jurors had read an article regarding the subject matter of the case published prior to trial. The Supreme Court reversed, holding that, under the circumstances of this case, the appellate court improperly determined that the trial judge abused his discretion in declining to poll the jury. View "Kervick v. Silver Hill Hosp." on Justia Law

Plaintiffs, Emilio and Maria D'Ascanio, filed an action for damages incurred as a result of personal injuries sustained by Emilio when he was operating a forklift designed, manufactured, and distributed by Defendants. Plaintiffs claimed that defects in the forklift proximately caused Defendant's injuries. During trial, Plaintiffs' expert witness presented testimony by showing a video of a forklift that was not the same model involved in this case. The trial court struck the testimony the expert had given and precluded him from testifying further. The trial court subsequently denied Plaintiffs' motions for a mistrial and a continuance. The court then granted a directed verdict for Defendants on the basis that Plaintiffs had not presented expert testimony that the forklift was defective. The appellate court reversed. The Supreme Court affirmed, holding that because Plaintiffs' conduct did not constitute a pattern of abuse so egregious as to warrant dismissal, the appellate court properly determined the trial court's rulings, considered in their entirety, constituted an abuse of discretion. View "D'Ascanio v. Toyota Indus. Corp." on Justia Law

Plaintiff, a construction company, agreed by contract to perform site work for Hoffman Enterprises on several parcels of property. Plaintiff later filed this action against Hoffman Enterprises and Jeffrey Hoffman for negligent misrepresentation, among other claims. The trial court granted Hoffman's motion to strike the negligent misrepresentation claim. The appellate court reversed. Hoffman appealed, asserting that Plaintiff could not, as a matter of law, satisfy the detrimental reliance element of its claim because Hoffman's apparent authority to bind Hoffman Enterprises contractually meant that Plaintiff could not have relied to its detriment on Hoffman's statements. The Supreme Court affirmed, holding (1) the fact that allegations pleaded in a complaint might also state a contractual claim against a corporate entity under the apparent authority doctrine does not preclude a separate claim of negligent misrepresentation against a principal of that corporate entity as a matter of law; and (2) Plaintiff pleaded a legally sufficient claim of negligent misrepresentation. View "Coppola Constr. Co. v. Hoffman Enters. Ltd. P'ship" on Justia Law

Plaintiff was injured when she rode her bicycle into a pipe gate on property maintained by Defendant, a water supply company. Plaintiff brought this action claiming that Defendant was negligent in its maintenance of the gate. After a trial, the jury awarded damages to Plaintiff. Defendant appealed, claiming that no reasonable juror could have found that the alleged negligence had an "inherently close connection" to Defendant's proprietary function of supplying water and that, in the alternative, it was entitled to immunity under the Recreational Land Use Act. The Supreme Court affirmed, holding (1) Defendant was liable because the maintenance of the gate was inextricably linked to a proprietary function; and (2) Defendant was not entitled to immunity pursuant to the Act. View "Blonski v. Metro. Dist. Comm'n" on Justia Law

Doctor was a physician who worked for Hospital on a study he claimed would assist in the treatment of children with abnormally low rates of growth. In actuality, Doctor was a child pornographer and pedophile and used the study as a cover to recruit and sexually exploit hundreds of children. The named plaintiff (Plaintiff), one of the exploited children, brought this action against Hospital alleging (1) Hospital negligently failed to supervise Doctor's activities in connection with the study, and (2) Hospital breached the special duty of care it owed to children in its custody. The trial court rendered judgment for Plaintiff on both claims and awarded him $2,750,000. The Supreme Court affirmed, holding that the trial court did not err in its instructions to the jury. View "Doe v. Saint Francis Hosp. & Med. Ctr." on Justia Law

Plaintiff filed this action for trespass after Defendant removed multiple trees on Plaintiff's property without Plaintiff's permission. The trial court rendered judgment in favor of Plaintiff and awarded damages reflecting the diminution in the value of Plaintiff's land as a result of the removal of the trees. The appellate court affirmed. Defendant appealed, contending that the appellate court improperly determined that Conn. Gen. Stat. 52-560, which Defendant claimed provides the exclusive measure of damages in a tree cutting case, does not preempt a common-law cause of action for intentional trespass under the circumstances here. The Supreme Court affirmed, holding that the appellate court properly concluded that section 52-560 does not preempt the common law but, rather, enhances the common law by providing for treble damages when the proper measure of damages is the reasonable value of the trees as timber. View "Caciopoli v. Lebowitz" on Justia Law