Justia Connecticut Supreme Court Opinion Summaries

A municipal tax collector initiated a bank execution action against an individual to collect unpaid personal property taxes owed by a business with which the individual was previously associated. The individual had moved to California years earlier and claimed that she never received notice of the tax debt or an opportunity to contest it, despite providing her new address to the tax collector. Previous bank executions had been initiated, but the individual continued to assert lack of notice. In the 2021 action, the trial court found that the tax collector failed to comply with statutory notice requirements and that the individual had not been afforded due process, leading the court to grant her exemption from the execution.Following the 2021 judgment, the tax collector withdrew its appeal and attempted a new bank execution after sending written demand to the individual's California address, but did not provide a new tax bill or opportunity to challenge it. The individual again moved for exemption. The Superior Court concluded that the new execution was a collateral attack on the previous judgment and was barred by doctrines of res judicata and collateral estoppel. The Appellate Court affirmed, finding that the issue of notice and opportunity to challenge the tax debt had been actually litigated and necessarily determined in the prior action.Upon review, the Connecticut Supreme Court held that collateral estoppel barred the municipal tax collector from relitigating whether it could execute on the individual's funds without first providing adequate notice and an opportunity to challenge the underlying tax debt. The Court determined that both independent, alternative grounds supporting the earlier judgment were entitled to preclusive effect and declined to create a public policy exception for municipal tax collection actions. The Supreme Court affirmed the judgment of the Appellate Court. View "Torrington Tax Collector, LLC v. Riley" on Justia Law

The plaintiffs, property owners in Danbury, Connecticut, challenged the tax assessments on their properties, each valued at over one million dollars, by appealing to the Superior Court. They were required by statute to file appraisals of their properties within 120 days of filing their appeals. The plaintiffs requested extensions to this deadline, which the court granted. However, they failed to file the appraisals with the court by the extended deadlines, although they did provide the appraisals to the defendant's counsel.The trial court initially dismissed five of the six tax appeals for failure to meet the filing deadline, concluding it lacked subject matter jurisdiction. The court later granted the plaintiffs' motions to open the judgments of dismissal and for reargument, citing similar cases where the court had not dismissed appeals under similar circumstances. The court denied the defendant's corrected motion to dismiss the sixth appeal, finding no prejudice to the defendant from the late filing.The defendant appealed to the Connecticut Supreme Court, arguing that the trial court lacked subject matter jurisdiction due to the plaintiffs' failure to timely file the appraisals. The plaintiffs contended that the appeal was moot because they had filed new tax appeals under a recent statutory amendment allowing for such actions if previous appeals were dismissed under certain conditions.The Connecticut Supreme Court held that the appeal was not moot, as the underlying appeals were not "dismissed" for purposes of the new statutory provision, given that the judgments of dismissal had been opened. The court further held that the appraisal filing requirement in § 12-117a (a) (2) is not subject matter jurisdictional. The requirement is mandatory but arises after the commencement of a tax appeal, and the time period for filing the appraisal can be extended by the court for good cause. The judgments of the Superior Court were affirmed. View "7 Germantown Road, LLC v. Danbury" on Justia Law

The plaintiff, a company that constructs and operates fuel cells, sought municipal property tax exemptions for its fuel cell modules and related equipment installed on the Pfizer campus. The property primarily provided electricity and converted waste heat into thermal energy. The plaintiff applied for tax exemptions under Connecticut General Statutes § 12-81 (57), which exempts class I renewable energy sources from taxation. The defendant, the town of Groton, denied the applications, classifying the property as a cogeneration system under § 12-81 (63), which allows but does not require municipalities to exempt such systems from taxation.The Superior Court granted partial summary judgment to the plaintiff, ruling that the property was exempt from taxation for the years 2017 through 2019 under § 12-81 (57). The court found that the property, which included fuel cells with a heat recovery steam generator (HRSG), fell within the definition of a class I renewable energy source. For the 2016 tax year, the court held a trial and determined that the property was not completely manufactured by October 1, 2016, and thus was exempt under § 12-81 (50) as "goods in the process of manufacture." The court also ruled that the plaintiff was not required to file a personal property declaration for the exempt property, and the penalties imposed by the defendant for failing to file such a declaration were improper.The Connecticut Supreme Court upheld the trial court's rulings. It agreed that the property was exempt from taxation under § 12-81 (57) for the years 2017 through 2019, as the statute specifically exempts class I renewable energy sources, including fuel cells. The court also affirmed that the property was exempt for the 2016 tax year under § 12-81 (50) as it was still in the process of manufacture. Finally, the court held that the plaintiff was not required to file a personal property declaration for the exempt property, and the penalties for failing to do so were not permitted. View "FuelCell Energy, Inc. v. Groton" on Justia Law

The case involves a dispute over the taxability of personal property used by a hospital at an outpatient rehabilitation facility. The plaintiff, a hospital owned by a health system, operates a rehabilitation facility in a leased suite. The plaintiff claimed that the personal property used at this facility was exempt from taxation under Connecticut General Statutes § 12-81 (7) or (16), which provide tax exemptions for charitable and hospital property, respectively. The town's assessor denied the tax exemption, and the town's board of assessment appeals upheld this denial.The trial court reviewed the case and sided with the plaintiff, granting its motion for summary judgment. The court reasoned that although the plaintiff is part of a health system, the personal property was located at a leased facility, not owned by the health system, and therefore did not fall under the purview of General Statutes § 12-66a. The court concluded that the personal property was exempt from taxation under § 12-81 (7) and (16).The Connecticut Supreme Court reviewed the case and reversed the trial court's decision. The Supreme Court held that the personal property used at the rehabilitation facility is taxable under § 12-66a, even if it would otherwise be exempt under § 12-81 (7) or (16). The Court determined that the term "acquired" in § 12-66a includes leased property, not just purchased property. The Court emphasized that the statute aims to protect municipalities from losing tax revenue due to health systems acquiring tax-exempt status for properties they use, whether owned or leased. The Court also clarified that the plaintiff, as part of a health system, falls under the statute's provisions, making the personal property taxable.The Supreme Court reversed the trial court's judgment and remanded the case with directions to deny the plaintiff's motion for summary judgment and for further proceedings. View "William W. Backus Hospital v. Stonington" on Justia Law

The case involves Alico, LLC, a Massachusetts-based company with offices in both Massachusetts and Connecticut. The company's vehicles, used for business, were registered in Massachusetts, and taxes were paid in that state. However, the vehicles were primarily used and garaged in Somers, Connecticut, where the company's sole member and his wife, who also works for the company, reside. In 2018, the tax assessor in Somers, Connecticut, became aware of the presence of these vehicles and retroactively placed them on the town's 2017 and 2018 grand lists, assessing property taxes on them. The plaintiffs, Alico and its sole member, appealed this decision, arguing it was unconstitutional under the dormant commerce clause of the United States constitution. They claimed that because the vehicles were used in interstate commerce and already taxed in Massachusetts, the Connecticut property tax led to impermissible double taxation.The Supreme Court of Connecticut disagreed with the plaintiffs' arguments. The court ruled that the property tax authorized by Connecticut's statute did not violate the dormant commerce clause. The court applied the test set forth in Complete Auto Transit, Inc. v. Brady, which determines the constitutionality of a state tax that is facially neutral but may impose a disproportionate burden on interstate commerce. The court found that the Connecticut tax was applied to an activity with a substantial nexus with the state, was fairly apportioned, did not discriminate against interstate commerce, and was fairly related to the services provided by the state. Therefore, the court affirmed the trial court's denial of the plaintiffs' request for a declaratory judgment declaring the assessments unconstitutional. The court also noted that any double taxation was not the result of a discriminatory tax scheme, but rather the plaintiffs' business decisions. View "Alico, LLC v. Somers" on Justia Law

The Supreme Court reversed the judgment of the trial court in favor of Defendant Barbara Lembo in this action brought by beneficiaries of an inter vivos trust and their mother alleging that Defendant breached her fiduciary duty as trustee, holding that the allegations in the complaint stated a legally sufficient claim for breach of a trustee's fiduciary duties under Connecticut law.The will of the decedent bequeathed the residue of his estate to an amended and restated revocable trust benefitting his three children. At issue was the proper administration of a portion of the decedent's residuary estate that had not yet been distributed to the trust. Plaintiffs brought this action alleging that Defendant, among other things, breached her fiduciary duty by failing to protect and collect trust property. The trial court concluded that Defendant, as a trustee, had no duty to take any action prior to the distribution of the residuary assets. The Supreme Court reversed, holding (1) a genuine issue of material fact remained as to whether Defendant owed the trust beneficiaries a duty to collect and protect the prospective trust property in the residuary estate; and (2) the complaint sufficiently alleged a cause of action against Defendant for breach of her fiduciary duty as trustee. View "Barash v. Lembo" on Justia Law

The Supreme Court affirmed the decision of the appellate court affirming the judgment of the trial court in favor of the town of Hamden in this tax dispute, holding that the appellate court correctly determined that the word "submit" in Conn. Gen. Stat. 12-63c(a) unambiguously requires that an assessor receive income and expense forms by June 1.Conn. Gen. Stat. 12-63c(a) requires the owners of certain rental property to "submit" income and expense information to their municipal tax assessor "not later than the first day of June." Plaintiff in this case mailed the relevant information on May 31, 2016, but the assessor did not receive the forms until June 2, 2016. The assessor imposed a ten percent penalty on Plaintiff. Plaintiff brought this action alleging that the penalty was improper because its timely mailing was sufficient under the statute. The trial court granted summary judgment for Defendant, and the appellate court affirmed. The Supreme Court affirmed, holding (1) the word "submit" requires receipt of the income and expense forms no later than June 1; and (2) the ten percent penalty imposed on Plaintiff pursuant to section 12-63(d) was valid. View "Seramonte Associates, LLC v. Town of Hamden" on Justia Law

The Supreme Court affirmed the judgment of the trial court determining that property used for a residential mental health treatment program was tax exempt under Conn. Gen. Stat. 12-81(7), holding that the court did not err.The trial court granted the exemption on the residential mental health treatment program on the grounds that it did not provide housing subsidized by the government and that any housing provided was temporary. The Supreme Court affirmed, holding (1) Defendant failed to establish that the trial court lacked subject matter jurisdiction; (2) the trial court properly found that the program's housing was temporary and therefore qualified for the exemption on that basis; and (3) therefore, the trial court correctly rendered summary judgment in favor of Plaintiffs. View "Rainbow Housing Corp. v. Cromwell" on Justia Law

In this appeal requiring the Supreme Court to determine the priority of tax liens levied on real property by the Georgetown Special Taxing District the Supreme Court reversed the judgment of the trial court subordinating liens acquired by Defendant to the Georgetown Fire District, holding that the fire district's tax liens were subordinate to those of Defendant, which, in turn, were subordinate to those of the town.Plaintiffs - the town of Redding, the Redding Water Pollution Control Commission, and Georgetown Fire District - brought this action to foreclose municipal liens against Defendant RJ Tax Lien Investments, LLC, who had been assigned real estate tax liens originally levied by the taxing district. The trial court granted the motions for partial summary judgment with respect to priority filed by the town and the fire district and rendered a judgment of strict foreclosure in favor of the town and the fire district. The Supreme Court reversed in part, holding that the trial court incorrectly concluded that Defendant's liens were subordinate to those of the fire district. View "Redding v. Georgetown Land Development Co., LLC" on Justia Law

The Supreme Court reversed the judgment of the Appellate Court insofar as it upheld the trial court's order directing Defendants to reimburse Plaintiff for property taxes and insurance premiums, holding that the ordered relief was inconsistent with the remedial scheme available to a mortgagee in a strict foreclosure.At issue was whether a trial court may order a mortgagor to reimburse a mortgagee for the mortgagee's advancements of property taxes and insurance premiums during the pendency of an appeal from a judgment of strict foreclosure. The trial court ordered Defendants to reimburse Plaintiff for such property tax and insurance premium payments, and the Appellate Court affirmed. The Supreme Court reversed in part, holding (1) the trial court abused its discretion in directing Defendants to make monetary payments to Plaintiff outside of a deficiency judgment; and (2) the Appellate Court's judgment is affirmed in all other respects. View "JPMorgan Chase Bank, National Ass'n v. Essaghof" on Justia Law