Justia Connecticut Supreme Court Opinion Summaries

Petitioner, an inmate at McDougall Correctional Institution, was found guilty of possession of contraband. After a hearing at which Petitioner was permitted to present witnesses and to testify on his own behalf, the Inmate Classification Administrator, ordered that Petitioner be placed in administrative segregation at Northern Correctional Institution, the state’s maximum security prison. Petitioner subsequently filed a habeas petition, which the habeas corpus denied. Petitioner appealed, arguing that the habeas court abused its discretion because it did not address his contention that his placement in administrative segregation violated his right to due process. The Appellate Court rejected Petitioner’s claims. The Supreme Court affirmed, holding (1) the Appellate Court incorrectly indicated that Connecticut prisoners can never establish a liberty interest in avoiding administrative segregation; (2) the Appellate Court incorrectly determined that the habeas court acted within its discretion in denying the petition for certification to appeal from the judgment of the habeas court because the habeas court’s reason for denying that petition was unsupportable; but (3) even if Petitioner had a liberty interest in avoiding his transfer to Northern, he received all of the process he was due prior to that transfer. View "Vandever v. Comm’r of Corr." on Justia Law

Plaintiffs, insurance producers who conduct business within the state and licensees of the Department of Insurance (department), filed a declaratory judgment action against the Commissioner of Insurance seeking declaratory rulings with respect to the legality of their conduct in the sale of life insurance policies. The trial court dismissed the action, concluding (1) Plaintiffs failed to exhaust their administrative remedies before bringing this declaratory judgment action pursuant to Conn. Gen. Stat. 4-175; and (2) Plaintiffs failed to establish their standing to bring this declaratory judgment action. The Supreme Court reversed, holding (1) the trial court improperly determined that Plaintiffs were not aggrieved parties with standing to bring this declaratory judgment action; and (2) the trial court improperly dismissed this declaratory judgment action on the ground that Plaintiffs had failed to exhaust their administrative remedies. View "Fin. Consulting, LLC v. Comm’r of Ins." on Justia Law

After a jury trial, Defendant was convicted of burglary in the first degree and kidnapping in the first degree. The Appellate Court vacated Defendant’s conviction and ordered a hearing to determine whether a competency evaluation was required, determining that the trial court had violated Defendant’s right to due process by failing to conduct a proper inquiry into Defendant’s competency. The Supreme Court affirmed, holding (1) the Appellate Court properly determined that the trial court’s independent inquiry into Defendant’s request for a competency evaluation was inadequate; (2) under the specific facts of this case, it was an abuse of the trial court’s discretion not to order a competency hearing; and (3) the remedy ordered by the Appellate Court was in line with United States Supreme Court precedent. Remanded. View "State v. Dort" on Justia Law

Defendant, who had an extensive weapons collection, was transporting a dirk knife, police baton and other weapons from his former residence in Connecticut to his new residence in Massachusetts when he was involved in a traffic accident. The State subsequently charged Defendant with six counts of having a weapon in a motor vehicle in violation of Conn. Gen. Stat. 29-38(a). A jury found Defendant guilty of two counts. The Supreme Court reversed, holding that the current statutory scheme, which categorically bars the transportation of a dirk knife and police baton by motor vehicle from a former residence to a new residence, impermissibly infringes on a person’s constitutional right under the second amendment to possess those weapons. View "State v. DeCiccio" on Justia Law

A union initiated arbitration proceedings after a police officer with the town of Stratford was terminated for lying in connection with his employment. A three-member arbitration panel determined that the officer’s termination was excessive and ordered that the town reinstate the officer. The town filed an application to vacate the arbitration award, arguing that the award encouraged police officer dishonesty and thereby violated public policy against lying by law enforcement personnel. The trial court denied the application. The Appellate Court reversed, concluding that the arbitration award violated a clear public policy against intentional dishonesty by police officers in connection with their employment. The Supreme Court reversed, holding (1) there is a public policy against intentional police officer dishonesty in connection with his or her employment, but (2) in this case, the arbitration award reinstating the officer’s employment did not violate that public policy. Remanded. View "Stratford v. AFSCME, Council 15, Local 407" on Justia Law

The Meridian city council acted upon the recommendation of the former mayor in appointing Defendant as corporation council for the city. Plaintiffs, taxpayers of the city, filed a petition of quo warranto seeking Defendant’s removal from the office of corporation council. The trial court granted the writ and ordered Defendant’s removal from the office, concluding that the Meridian city charter clearly and unambiguously required the current mayor to recommend all appointments to offices or positions within the city. The Supreme Court affirmed, holding that the trial court properly determined that the charter required the recommendation of the mayor for the appointment of the corporation counsel for the city. View "DeMayo v. Quinn" on Justia Law

After a jury trial, Defendant was convicted of two counts of risk of injury to a child. The Appellate Court affirmed. The Supreme Court affirmed, holding (1) Defendant’s claim of error in the admission of out-of-court statements of one of the victims through the testimony of a police officer to provide context for Defendant’s admission to the conduct underlying the charges against him was not properly preserved; (2) even assuming that certain out-of-court statements of one of the victims that were admitted through the testimony of the state’s expert as examples of their age inappropriate knowledge were improperly admitted, any impropriety was harmless; and (3) Defendant was not deprived of a fair trial by any purported prosecutorial impropriety. View "State v. Paul B." on Justia Law

Approximately ten years after Plaintiff and Defendant were divorced, Plaintiff moved for modification of the stipulated alimony award on grounds that the circumstances of the case had changed substantially because Defendant’s income and Plaintiff’s medical costs had both increased significantly. The trial court granted Plaintiff’s motion for modification and substantially increased the amount of alimony that Defendant was required to pay Plaintiff. Defendant appealed, arguing that the trial court improperly granted Plaintiff’s motion for modification solely on the basis of Defendant’s increased income. The Supreme Court reversed, holding (1) in the absence of certain exceptional circumstances, an increase in income, standing alone, does not justify the modification of an alimony award; and (2) because the trial court made no findings as to whether exceptional circumstances existed in the present case, the case must be remanded for a new hearing at which the trial court may apply the proper standard in making such a finding. View "Dan v. Dan" on Justia Law

The parties in this case - a board of education and an education association - proceeded to arbitration on a dispute. The parties proceeded on a three member arbitration panel. When a journalist with a newspaper sought to cover the arbitration proceedings, the panel adjourned to what it designated an executive session, closed to the public. The journalist and newspaper (together, Defendants) filed a complaint with the Freedom of Information Commission, claiming that the panel violated the open meetings provision of the Freedom of Information Act (FOIA). The Commission ordered the members of the arbitration panel and the Department to create a transcript of the hearing and provide that transcript to Defendants, concluding that the arbitration panel was a committee of the Department of Education and that the evidentiary portion of the arbitration proceeding under the Teacher Negotiation Act (TNA) was subject to the open meetings provision of the FOIA. The Supreme Court reversed, holding that because a TNA arbitration panel is not a “committee of” the Department, it does not constitute a “public agency.” View "Gould v. Freedom of Info. Comm’n" on Justia Law

Plaintiff filed suit against Defendants, Plaintiff's employer and manager, alleging that she was discriminated against on the basis of her physical disability and/or her perceived disability, among other claims. The trial court granted summary judgment for Defendants on the disability discrimination claim to the extent that it alleged a cause of action based on a perceived physical disability, concluding that a cause of action based on a perceived disability is not a legally recognized action in Connecticut. The Appellate Court affirmed. The Supreme Court reversed in part, holding that the Connecticut Fair Employment Practices Act not only protects individuals who have a physical disability, but also individuals who are regarded by their employers as having a physical disability. View "Desrosiers v. Diageo N. Am., Inc." on Justia Law