Justia Connecticut Supreme Court Opinion Summaries

The Supreme Court affirmed the decision of the Compensation Review Board, which reversed the decision of the Workers' Compensation Commissioner denying benefits to Plaintiff pursuant to Conn. Gen. Stat. 7-433c(a), holding that the Board incorrectly determined that Plaintiff's heart disease claim was untimely.The Commissioner found that Plaintiff was neither diagnosed with heart disease nor filed a claim for that disease under section 7-433c until after he had retired. Therefore, the Commissioner concluded that Plaintiff's disease and resulting disability were not suffered while Plaintiff was employed by Defendant and that even if Plaintiff was developing heart disease while he was employed by Defendant that was not sufficient to make the claim compensable. The Board reversed, concluding that it was reasonable to infer that Plaintiff's heart disease was the sequela of his accepted claim under section 7-433c for hypertension. The Supreme Court affirmed, holding (1) Plaintiff's initial claim for hypertension met the requirements of section 7-433c, was timely, and was compensable; and (2) the Board reasonably concluded that Plaintiff's heart disease was the sequela of his hypertension, which was the injury at issue in his primary claim. View "Coughlin v. Stamford Fire Department" on Justia Law

The Supreme Court affirmed the decision of the Compensation Review Board, which vacated the decision of the Workers' Compensation Commissioner dismissing Plaintiff's claim for benefits brought pursuant to Conn. Gen. Stat. 7-433c(a), holding that Plaintiff met the jurisdictional prerequisites of section 7-433c and that, on remand, the Commissioner shall determine whether Plaintiff's hypertension was a substantial factor in his subsequent development of heart disease.The Commissioner found that Plaintiff was not entitled to benefits for heart disease because he failed to file a notice of new claim within one year of his diagnosis. In making this finding, the Commissioner rejected Plaintiff's argument that his heart disease diagnosis was the sequela of his compensable claim for hypertension. The Board vacated the Commissioner's dismissal because the Commissioner did not present findings as to whether Plaintiff's heart disease was caused by his hypertension or constituted a new injury. The Supreme Court affirmed and remanded the case, holding (1) when a plaintiff has a compensable claim for hypertension under section 7-433c, the plaintiff may also be eligible for benefits for subsequent heart disease if his heart disease is causally related to his hypertension; and (2) Plaintiff was not required to file a notice of new claim in order to pursue benefits for his heart disease. View "Dickerson v. Stamford" on Justia Law

In this action to recover damages for personal injuries resulting from an allegedly defective product the Supreme Court reversed the judgment of the trial court granting summary judgment in favor of Defendants, holding that the amendment to the statute of repose in Number 17-97 of the 2017 Public Acts (P.A. 17-97) retroactively applied to Plaintiff's claims.On appeal, Plaintiff argued that the statute of repose applied to her product liability claims is unconstitutional because it creates two classes of claimants - employees subject to a ten-year statute of repose and nonemployees not subject to the statute of repose if the claimant shows the product was within its useful safe life when the injury occurred. While Defendants' motions for summary judgment were pending the legislature enacted P.A. 17-97, which combined the two classes of claimants by removing the limitation provision applicable to employees. The trial court concluded that P.A. 17-97 was not retroactive and applied the ten-year statute of repose to bar Plaintiff's claims. The Supreme Court reversed, holding that the amendment to the statute of repose in P.A. 17-97 retroactively applied to Plaintiff's claims. The Court remanded to determine whether there is a genuine issue of material fact as to whether the injury occurred during the safe life of the product. View "King v. Volvo Excavators AB" on Justia Law

In this case concerning the proper recipient of heart and hypertension benefits under Conn. Gen. Stat. 7-433c for permanent disability if such benefits vested and were payable during the claimant's lifetime but were not paid to the claimant before his death the Supreme Court reversed the decision of the Compensation Review Board concluding that the executrix of the decedent's estate was improperly was substituted as party claimant, holding that heart and hypertension benefits under § 7-433c may be paid to a claimant’s estate if such unpaid benefits matured before the claimant’s death.The Workers' Compensation Commissioner granted the motion to substitute the executrix as a party claimant. The Board concluded that the executrix was improperly substituted as party claimant because a claimant's estate cannot receive the claimant's vested but unpaid section 7-433c benefits. The Supreme Court disagreed, holding (1) neither Morgan v. East Haven, 546 A.2d 243 (Conn. 1988), nor any other legal authority barred the substitution to the extent that the executrix sought payment of matured benefits; but (2) because the record did not support the determination that the decedent's section 7-433c disability benefits matured before his death, this case must be remanded for further proceedings to decide the proper beneficiary of any benefits due. View "Brennan v. Waterbury" on Justia Law

In this dispute between the Board of Education of the Town of New Milford (Board) and the New Milford Education Association (Union) the Supreme Court affirmed the judgment of the trial court denying the Board's application to vacate a grievance arbitration award and granting the Union's application to confirm the grievance arbitration award, holding that the arbitrator did not manifestly disregard the law and properly concluded that the Union's grievance was arbitrable.The Union, which represented the teachers employed by the Board, filed a grievance alleging that the Board had violated an agreement between the parties. The arbitrator decided the grievance in the Union's favor. The trial court denied the Board's application to vacate the grievance arbitration award and granted the Union's application to confirm the award. The Supreme Court affirmed, holding that the trial court (1) correctly denied the Board's application to vacate the grievance arbitration award on the grounds that the arbitrator manifestly disregarded the law by concluding that the doctrines of collateral estoppel and res judicata did not apply to bar the Union's grievance; and (2) the trial court properly concluded that the Union's grievance was arbitrable under the terms of the agreement. View "Board of Education of Town of New Milford v. New Milford Education Ass'n" on Justia Law

The Supreme Court reversed the decision of the Compensation Review Board affirming the decision of the Workers' Compensation Commissioner concluding that Plaintiff was not an employee of Intervale Group, LLC for purposes of the Workers' Compensation Act, holding that Plaintiff qualified as Intervale's employee for purposes of the Act and, therefore, was eligible for concurrent compensation benefits pursuant to Conn. Gen. Stat. 31-310.Plaintiff was the sole member of Intervale, a single-member limited liability company. Plaintiff was employed part-time by the City of Stamford. After he was injured while working for the City, Plaintiff sought compensation based on the earnings that he received from both the City and Intervale, claiming that he was concurrently employed by Intervale. The City transferred the concurrent compensation obligation to the Second Injury Fund, which denied the claim for benefits on the ground that Plaintiff was not Intervale's employee. The Commissioner concluded that Plaintiff was not an employee of Intervale, and the Board affirmed. The Supreme Court reversed, holding that because Plaintiff provided services to Intervale and was subject to the hazards of Intervale's business, Plaintiff was Intervale's employee for purposes of the Act. View "Gould v. Stamford" on Justia Law

In this workers’ compensation case, the Supreme Court held that Defendant-employer was collaterally estopped from challenging an employee’s eligibility for benefits under the Workers’ Compensation Act (state act), Conn. Gen. Stat. 31-275 et seq., because of an earlier decision by a United States Department of Labor administrative law judge (ALJ) awarding benefits to the employee under the federal Longshore and Harbor Workers’ Compensation Act (Longshore Act), 33 U.S.C. 901 et seq.The Supreme Court affirmed the decision of the Compensation Review Board (Board) reversing the decision of the Workers’ Compensation Commissioner dismissing the claims for benefits under the state act filed by Plaintiff, the executor of the decedent’s estate and the decedent’s widow. The Court held that the Board properly determined that the employer in this case was collaterally estopped from relitigating the issue of causation under the state act because the record of the Longshore Act proceedings indicated that the ALJ employed the substantial factor standard that governed the proceedings under the state act. View "Filosi v. Electric Boat Corp." on Justia Law

At issue was the extent of an employer’s right to a credit against its obligation to pay workers’ compensation benefits for an injured employee who has recovered damages from a third-party tortfeasor that caused the employee’s injuries.Under an amendment to Conn. Stat. 31-293(a), even if the employer is owed more than is recovered in the third-party action, the employee retains one-third of the proceeds for her sole benefit. In dispute was whether the employer has a right to a setoff against its obligation to pay for post-judgment workers’ compensation benefits until those benefits exceed the one-third portion that the employee received from the proceeds of the third-party action.The Compensation Review Board affirmed the decision of the workers’ compensation commissioner that the defendant employer was entitled to a “moratorium,” or the credit afforded the employer against any later arising benefits in the amount of any proceeds the employee received in the third-party action. The Supreme Court reversed, holding that the employee’s one-third portion is not subject to the moratorium because the application of the moratorium to the one-third reduction would conflict with and undermine the purpose of P.A. 11-205, which amended section 31-293(a). Moreover, the legislature intended for the employee alone to retain the benefit of the one-third reduction. View "Callaghan v. Car Parts International, LLC" on Justia Law

Conn. Gen. Stat. 31-51bb permitted Plaintiff to file a claim with the Workers’ Compensation Commission alleging that the City of New Haven had violated Conn. Gen. Stat. 31-290a by wrongfully terminating his employment in retaliation for bringing a workers’ compensation claim, notwithstanding that a related issue had previously been decided by the State Board of Mediation and Arbitration in an arbitration proceeding brought pursuant to Plaintiff’s collective bargaining agreement.The Compensation Review Board determined that, under section 31-51bb, Plaintiff’s claim brought before the Commission pursuant to section 31-290a was not barred by the doctrine of collateral estoppel. The Supreme Court affirmed, holding that section 31-51bb permitted Plaintiff to file a claim with the Commission pursuant to section 31-290a under the circumstances of this case. View "Williams v. City of New Haven" on Justia Law

The Supreme Court affirmed the decision of the trial court rendering judgment in favor of Plaintiff on its claim of unjust enrichment.On appeal, Defendant argued that Plaintiff’s unjust enrichment claim was barred by collateral estoppel, that Plaintiff’s recovery was precluded by law and the terms of an agreement between the parties, the trial court’s jury instructions were improper, and the trial court erred in excluding certain evidence. In affirming, the Court held that many of Defendant’s arguments were unpreserved, inadequately briefed, or both, and that Defendant was not entitled to relief on any of his assignments of error. View "MacDermid, Inc. v. Leonetti" on Justia Law