Justia Connecticut Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of sexual assault in the first degree, sexual assault in the fourth degree, and risk of injury to a child. The Supreme Court affirmed, holding (1) even though Defendant was only fourteen and fifteen years old when he committed the crimes, the trial court did not err in imposing the mandatory minimum sentences for the first degree sexual assault conviction and the risk of injury conviction, as the mandatory minimum requirements left the trial court with broad discretion to fashion an appropriate sentence that accounted for Defendant’s youth and immaturity when he committed the crimes; (2) the state’s expert witness did not improperly vouch for the credibility of the victim; and (3) Defendant’s argument that the trial court improperly admitted evidence of sexual misconduct committed by Defendant when he was thirteen years old on propensity grounds was unpreserved for appeal. View "State v. Taylor G." on Justia Law

Plaintiffs were employees of Employers when they each suffered compensable injuries. Plaintiffs were treated at two different hospitals. In each case, the hospital submitted a bill for its services to Employer. Employer paid each hospital in accordance with the cost assessment of a third-party bill reviewer, which in each case was significantly less than what had been billed by the hospital. The hospitals subsequently sought to have the workers’ compensation commissioner determine Employer’s liability for the hospital costs. At issue was whether Employer’s liability for the hospital services should be assessed on the basis of the commissioner’s determination of what it “actually cost” the hospitals to render the services, as provided under Conn. Gen. Stat. 31-294d(d), or on the basis of the hospitals’ published rates that they are required to charge “any payer” under Conn. Gen. Stat. 19a-646. The commissioner concluded that the two cases were controlled by Burge v. Stonington, in which the Supreme Court concluded that the “actually costs” language in the predecessor to section 31-294d(d) had been repealed or preempted in 1973 when the legislature first regulated hospital rates. The Supreme Court affirmed, holding that the public health scheme governing hospital rates for payers generally controlled the cases here. View "Caraballo v. Elec. Boat Corp." on Justia Law

The named plaintiff in this putative class action and her daughter (together, Plaintiffs) were injured in motor vehicle accidents. Defendant, which administered the Medicaid program for the state and was the designated assignee of the Department of Social Services under Conn. Gen. Stat. 17b-265, paid for the medical care that Plaintiffs received as a result of their injuries. After Plaintiffs brought civil actions against the tortfeasors, Defendant, acting through its agent, sought to recover from Plaintiffs the amounts they recovered from the tortfeasors as reimbursement for the payments made by Defendant for Plaintiffs’ medical care. Plaintiffs brought this action seeking, inter alia, a declaratory judgment that section 17b-265 did not authorize Defendant to seek reimbursement from them but required Defendant to seek recovery directly from the liable third parties. The trial court granted summary judgment for Defendant. The Appellate Court affirmed. The Supreme Court affirmed, holding that the Appellate Court did not err in concluding that section 17b-265 permitted Defendant to seek reimbursement from Plaintiffs and other similarly situated persons for amounts that they recover from liable third parities for medical costs. View "Rathbun v. Health Net of the Northeast, Inc." on Justia Law

In Miller v. Alabama, the U.S. Supreme Court held that mandatory sentencing schemes that impose on juvenile offenders a term of life imprisonment without parole violate the Eighth Amendment. At issue in this case was whether a life sentence without parole may be imposed on a juvenile homicide offender in the exercise of the sentencing authority’s discretion. Defendant, who was seventeen years old at the time of the crimes leading to his convictions, was convicted of murder and other crimes. Defendant was sentenced to a total effective sentence of 100 years imprisonment, which was the functional equivalent to life without the possibility of parole. The Supreme Court reversed, holding (1) in considering whether to sentence a juvenile to a discretionary sentence of life imprisonment without the possibility of parole, the sentencer is required to take into account the factors that Miller deemed constitutionally significant before determining that such severe punishment is appropriate; and (2) in light of the uncertainty of Defendant’s sentence upon due consideration of the Miller factors, a new sentencing proceeding must be held that conforms with the dictates of Miller. View "State v. Riley" on Justia Law

In 2009, the dissolution court dissolved the marriage of James and Diana Jordan. The court ordered that, after payment of attorneys fees and other obligations, the balance of the parties’ account at Northwestern Mutual (account) be divided equally between the parties. Plaintiff, Diana’s father, brought this action against James to collect the outstanding balance on James’s promissory note to him. The trial court entered judgment in favor of Plaintiff. James then filed a claim for a determination of interests in the account. Defendants, the attorney and firm that represented James in the dissolution action, also sought a determination of interests in the account, claiming that they had a claim prior in right to Plaintiff’s claim by virtue of the charging lien arising by operation of law in the dissolution action. The trial court concluded that Defendants had no superior interest in the account because a charging lien in connection with a dissolution action would be prohibited by the Rules of Professional Conduct. The Appellate Court reversed. The Supreme Court reversed, holding that attorneys are not entitled by operation of law to equitable charging liens on marital assets for fees and expenses incurred in obtaining judgments for their clients in marital dissolution proceedings. View "Olszewski v. Jordan" on Justia Law

Plaintiff filed an amended revised complaint alleging that he suffered personal injury and damages that were caused by the negligence and carelessness of Defendant, the Town of Orange. Defendant filed a motion to dismiss, arguing that the trial court lacked subject matter jurisdiction over Plaintiff’s claim because Plaintiff failed to comply with the notice requirement of the municipal highway defect statute, Conn. Gen. Stat. 13a-149. The trial court agreed with Defendant and dismissed the complaint for lack of subject matter jurisdiction. Plaintiff appealed, claiming that because he did not assert his claim under section 13a-149, the trial court should not have found that Defendant could raise its jurisdiction argument regarding section 13a-149 in a motion to dismiss. The Appellate Court reversed on the ground that the facts in the record did not support a determination that Plaintiff’s claim fell within the ambit of section 13a-149. The Supreme Court affirmed, holding that because a factual dispute regarding jurisdiction remained unresolved at this stage of the proceedings, the Appellate Court properly reversed the trial court’s decision to dismiss Plaintiff’s action. View "Cuozzo v. Orange" on Justia Law

Plaintiff, a restaurant supply company, leased commercial property from Defendant. The lease provided Plaintiff and the guarantor with the option to purchase the premises during the term of the lease. In a separate provision, the lease required Defendant to perform environmental remediation on the premises. Plaintiff told Defendant that it had elected to exercise the option to purchase the premises but that, before the parties could close on the transaction, Defendant had to fulfill its obligation to complete the environmental remediation. Plaintiff, however, never attempted to tender payment of the purchase price. Plaintiff subsequently filed this action requesting that the trial court order specific performance of the option to purchase provision in the lease. The trial court declined to order specific performance. The Appellate Court affirmed, concluding that Plaintiff had failed to exercise the option to purchase in accordance with its terms. The Supreme Court affirmed, holding (1) because Plaintiff did tender the purchase price as required, it failed to exercise the option to purchase when the option was available; and (2) the doctrine of frustration of purchase did not apply in this case because Defendant’s lack of environmental remediation did not interfere with the purpose of the lease. View "Howard-Arnold, Inc. v. T.N.T. Realty, Inc." on Justia Law

After a jury trial, Defendant was convicted of one count of murder. On appeal, Defendant asserted that the trial court abused its discretion by (1) excusing a juror for injecting extraneous matters into deliberations and for refusing to deliberate; (2) excusing a second juror who was absent for one day without inquiring how long she would be unavailable; and (3) admitting into evidence testimony and a video recording relating to Defendant's refusal to cooperate with the police as they were taking a buccal swab from him. The Supreme Court affirmed, holding that the trial court did not abuse its discretion in (1) excusing the two jurors from the jury; (2) denying Defendant’s motions for a mistrial after the court excused the two jurors; and (3) admitting, as consciousness of guilt evidence, the testimony and video record of Defendant’s refusal to cooperate with the police. View "State v. Gonzalez" on Justia Law

Plaintiff, who worked for United Parcel Service, Inc. (UPS) for thirty-two years, was diagnosed with diabetes in 1987 and with diabetic neuropathy in 1998. The diabetic neuropathy caused impairment to his arms and hands. In 2003, Plaintiff suffered injuries to his upper arms and hands in a work-related accident. After Plaintiff retired in 2008 he filed a claim for benefits. The Workers’ Compensation Commissioner apportioned the payment so that Defendants, UPS and its insurer, paid only for the proportion of disability attributed to Plaintiff’s occupational injuries rather than pay the entirety of Plaintiff’s permanent partial disability to his upper extremities and hands. The Workers’ Compensation Board affirmed. The Appellate Court reversed. The Supreme Court affirmed, holding that a disability arising from a progressive nonoccupational condition - such as Plaintiff’s diabetes and diabetic neuropathy - that manifests prior to an occupational injury and that further disables the same body part is a compensable preexisting injury rather than a noncompensable concurrently developing disease under the apportionment rule established in Deschenes v. Transco, Inc. View "Sullins v. United Parcel Serv., Inc." on Justia Law

After a jury trial, Defendant was found guilty of robbery in the first degree as an accessory and conspiracy to commit robbery in the first degree. The jury further found that a firearm had been used in the commission of the robbery, and therefore, the trial court concluded that Defendant was subject to a sentence enhancement under Conn. Gen. Stat. 53-202k, which provides for a mandatory term of imprisonment when a person uses, or is armed with and threatens to use, a firearm in the commission of a felony. Defendant was unarmed when the robbery occurred. On appeal, Defendant argued, among other things, that she was not subject to sentence enhancement under section 53-202k because that provision should be construed to apply only to persons who either use a firearm in the commission of the offense or intend that another participant in the offense do so. The Supreme Court affirmed, holding (1) the evidence was sufficient to support Defendant’s convictions; (2) in light of the Court’s decision in State v. Flemke, decided today, Defendant was subject to sentence enhancement under section 53-202k; and (3) the trial court properly instructed the jury regarding the state’s burden of proof. View "State v. Danforth" on Justia Law