Justia Connecticut Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the appellate court upholding the trial court's denial of Defendant's motion for remittitur in this wrongful termination action, holding that the appellate court did not err in affirming the judgment of the trial court denying Defendant's motion for remittitur.Plaintiff brought this action for wrongful termination in violation of public policy stemming from his termination from employment as a truck driver after he raised complaints to Defendant regarding the safety of Defendant's vehicles. The jury returned a verdict for Plaintiff and awarded him damages for lost wages. Thereafter, Defendant filed several postverdict motions, including his motion for remittitur seeking to reduce the damages award to zero dollars. The trial court denied the motions. Plaintiff appealed, and Defendant cross-appealed, claiming that the trial abused its discretion in failing to set aside the jury's award. The appellate court affirmed. The Supreme Court affirmed, holding that there was no error in the damages award. View "Roach v. Transwaste, Inc." on Justia Law

The Supreme Court reversed the judgment of the appellate court concluding that there was not substantial record evidence to support the determination of the presiding human rights referee's determination of intentional discrimination in this action challenging an employment termination decision, holding that the appellate court erred.The referee determined that the Hartford Police Department had discriminated against Hoa Phan, a probationary police officer on the basis of his Vietnamese and Asian ancestry by terminating his employment. The trial court affirmed. The appellate court reversed, ruling that the trial court erred in finding that substantial evidence supported the referee's finding of intentional discrimination. The Supreme Court reversed, holding (1) the referee correctly determined that Phan had established his prima facie case; and (2) the appellate court's alternative holding that substantial evidence did not support the referee's finding of intentional discrimination was erroneous. View "Hartford Police Dep't v. Commission on Human Rights & Opportunities" on Justia Law

The Supreme Court reversed the judgment of the appellate court affirming the decision of the Compensation Review Board upholding the finding and award of the Workers' Compensation Commissioner for the Second Districting ordering the town of Waterford to accept as compensable Plaintiff's claim for heart disease benefits pursuant to Conn. Gen. Stat. 7-433c, holding that the appellate court erred.In concluding that Plaintiff was entitled to benefits the Commissioner determined that section 7-433c does not define the phrase "uniformed member of a paid municipal fire department." The appellate court affirmed. On appeal, the town argued that the appellate court erred in determining that the definition of "member" in Conn. Gen. Stat. 7-425(5) does not govern whether the plaintiff was a uniformed member of a paid municipal fire department for purposes of section 7-433c. The appellate court affirmed. The Supreme Court reversed, holding that the definition of "member" in section 7-425(5) governs eligibility for benefits under section 7-433c. View "Clark v. Waterford, Cohanzie Fire Dep't" on Justia Law

In these actions to recover underinsured motorist benefits allegedly due under certain automobile insurance coverage provided by the State pursuant to a collective bargaining agreement the Supreme Court held that the appellate court incorrectly concluded that the trial court should have reduced one appellant's award by the sums received in settlement of a claim under Connecticut's Dram Shop Act, Conn. Gen. Stat. 30-102.The trial court found for Appellants on liability but awarded only a fraction of the damages sought, due in part to the court's rejection of Appellants' PTSD claim. The appellate court reversed in part, concluding that the trial court's failure to reduce Appellants' damages by their dram shop recovery violated the common-law rule against double recovery. The Supreme Court reversed in part, holding that the appellate court (1) properly affirmed the trial court's conclusion that Appellants were not entitled to recover underinsured motorist benefits for alleged PTSD; and (2) improperly reversed the judgments insofar as the trial court determined that the State was not entitled to a reduction in the awards for sums received by Appellants in settlement of a dram shop claim. View "Menard v. State" on Justia Law

The Supreme Court reversed the decision of the appellate court affirming the order of the superior court granting Defendant's motion for summary judgment as to the first count of Plaintiff's complaint in this action to recover damages for the allegedly wrongful discharge of Plaintiff, holding that summary judgment was improper.Defendant, a helicopter flight training school, hired Plaintiff as a flight instructor. When Plaintiff refused to share fees that he expected to receive as a Federal Aviation Administration certified pilot examiner Defendant terminated his employment. Plaintiff brought this action alleging wrongful discharge in violation of the public policy embodied in Conn. Gen. Stat. 31-73(b). The Supreme Court held that the appellate court improperly upheld the trial court's summary judgment for Defendant because genuine material questions of fact remained. View "Dunn v. Northeast Helicopters Flight Services, LLC" on Justia Law

The Supreme Court reversed the decision of the appellate court reversing the judgment of the trial court finding that Defendant had discriminated against Plaintiff during the course of her employment by failing to provide reasonable accommodations for her disability, in violation of the Connecticut Fair Employment Practices Act, Conn. Gen. Stat. 46a-60(b)(1), and had unlawfully retaliated against her, holding that the trial court did not err.In reversing the judgment of the trial court, the appellate court concluded that the trial court improperly admitted into evidence written settlement communications, in violation of Conn. Code Evid. 4-8 and that the error was prejudicial. The Supreme Court reversed, holding (1) the trial court did not abuse its discretion in admitting the written communications into evidence; and (2) the other evidentiary errors identified by the appellate court were harmless. View "Kovachich v. Dep't of Mental Health & Addiction Services" on Justia Law

The Supreme Court affirmed the judgment of the appellate court upholding the trial court's determination affirming the decision of the Board of Review of The Employment Security Appeals Division that tattoo services are part of the usual course of business of a body art and piercing business for purposes of the statutory ABC test used to determined whether an individual is an employee for purposes of the Unemployment Compensation Act, Conn. Gen. Stat. 31-222 et seq., holding that there was no error.Plaintiff, a business that provides body piercing and body art services, argued on appeal that the Board acted unreasonably and arbitrarily in holding it liable for unpaid unemployment compensation contributions after concluding that the offering of tattoo services was within Plaintiff's usual course of business. The Supreme Court affirmed, holding that substantial evidence existed to support the Board's determination that tattoo services were within Plaintiff's "usual course of business" for purposes of part B of the ABC test. See Conn. Gen. Stat. 31-222(a)(1)(B)(ii)(II). View "Vogue v. Administrator, Unemployment Compensation Act" on Justia Law

The Supreme Court affirmed the judgment of the appellate court concluding that the Home Improvement Act (Act), Conn. Gen. Stat. 20-418 et seq., did not apply to work performed by Defendant on Plaintiff's property, holding that Plaintiff's claim under the Act was unavailing.The trial court found in favor of Plaintiff on his claims alleging breach of contract, violations of the Act, and violations of the Connecticut Unfair Trade Practices Act (CUTPA), Conn. Gen. Stat. 42-110a et seq. The trial court ruled in favor of Plaintiff. The appellate court affirmed with respect to the breach of contract count but reversed with respect to the remaining claims, ruling that the work performed by Defendant fell within the new home exception of the Act, and therefore, Plaintiff failed to state a claim under both the Act and CUTPA. The Supreme Court affirmed, holding that the work performed by Defendant fell within the new home exception. View "Winakor v. Savalle" on Justia Law

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

The Supreme Court affirmed the judgment of the trial court granting the application of Defendant, AFSCME, Council 4, Local 344 (Union), to confirm an arbitration award reinstating Nichole Jefferson to her employment as executive director of the City of New Haven's Commission on Equal Opportunities, holding that the trial court did not err in determining that the award did not violate public policy.The Union filed a grievance, claiming that the City did not have just cause to terminate Jefferson. The arbitration panel reinstated Jefferson to her employment. Thereafter, the trial court issued an order granting the Union's application to confirm the award and denying the City's corresponding application to vacate, concluding that Jefferson's reinstatement did not violate public policy. The Supreme Court affirmed, holding that the City failed to meet its burden of demonstrating that Jefferson's reinstatement violated public policy. View "New Haven v. AFSCME, Council 4, Local 3144" on Justia Law