Justia Connecticut Supreme Court Opinion Summaries

Plaintiff filed, among other claims, state law claims for negligence and negligent infliction of emotional distress against Defendant, a health care provider, alleging that Defendant improperly breached the confidentiality of Plaintiff’s medical records in the course of complying with a subpoena. The trial court dismissed Plaintiff’s negligence based claims, concluding that they were preempted by the Health Insurance Portability and Accountability Act of 1996 (HIPAA), which lacks a private right of action and preempts contrary state laws. The Supreme Court reversed, holding that HIPAA did not preempt Plaintiff’s state common-law causes of action for negligence or negligent infliction of emotional distress against Defendant because (1) Connecticut’s common law provides a remedy for a health care provider’s breach of confidentiality in the course of complying with a subpoena; and (2) HIPAA and its implementing regulations may be utilized to inform the standard of care applicable to claims arising from allegations of negligence in the disclosure of patients’ medical records pursuant to a subpoena. View "Byrne v. Avery Ctr. for Obstetrics & Gynecology, P.C." on Justia Law

After a jury trial, Defendant was convicted of assault of public safety personnel and engaging police in pursuit. During trial, the trial court required the jury, if it chose to watch a digital video exhibit again during its deliberations, to view it in open court rather than providing the jury with the equipment needed to watch the video in the privacy of the jury room. The Appellate Court affirmed the convictions, concluding that this procedure complied with the mandate, set forth in Practice Book 42-23(a), that the trial court “shall submit” to the jury all exhibits received in evidence for review during its deliberations. The Supreme Court affirmed, holding that a trial court has discretion, pursuant to its inherent authority to manage the trial process, to determine the means by which the jury reviews submitted evidence during its deliberations, and therefore, the trial court did not abuse its discretion in this case. View "State v. Jones" on Justia Law

After a jury trial, Appellant was convicted of tampering with physical evidence in violation of Conn. Gen. Stat. 53a-155, attempt to commit robbery in the third degree, and conspiracy to commit robbery in the third degree. The Appellate Court affirmed. The Supreme Court affirmed in part and reversed in part, holding (1) the Appellate Court properly concluded that the prosecutor’s failure to correct potentially misleading testimony of two witnesses did not violate Appellant’s due process right to a fair trial; (2) the Court's prior construction of section 53a-155 in State v. Foreshaw is not overruled; and (3) under a proper understanding of Foreshaw, the evidence was not sufficient to support Appellant’s conviction for tampering with physical evidence in violation of 53a-155. Remanded. View "State v. Jordan" on Justia Law

This case concerned a dispute between an insurance carrier (Plaintiff) and its insured (Defendant) regarding Plaintiff’s obligation to pay underinsured motorist benefits. An arbitration panel concluded that the issue of whether the relevant policy provisions provided coverage for the claim should be resolved under the choice of law rules governing claims sounding in tort, rather than claims sounding in insurance and contract, and therefore, that New Jersey law rather than Connecticut law governed Defendant’s claim for uninsured motorist benefits under the policy. The trial court vacated the arbitration award, and the Appellate Court affirmed. The Supreme Court affirmed, holding that the Appellate Court, in its opinion adopting the decision of the trial court, properly applied sections 6(2), 188 and 193 of the Restatement (Second), contract choice of law, to determine that Connecticut law governed the claim. View "Gen. Accident Ins. Co. v. Mortara" on Justia Law

Plaintiff, individually and as the parent and next friend of her minor son, brought this action against the City of Middletown, alleging that her son had been injured when he was pushed into the edge of a broken locker at Middletown High School. Defendant raised as a special defense that it was immune from liability. The jury ultimately rendered a verdict in favor of Plaintiffs. The trial court, however, granted Defendant’s motion to set aside the verdict and to render judgment for Defendant on the ground of governmental immunity. The Appellate Court affirmed on the alternative ground that Plaintiffs had not pleaded the imminent harm to identifiable persons exception in its reply to Defendant’s special defense. The Supreme Court reversed. On remand, The Appellate Court concluded that the trial court properly determined, on the basis of the arguments the parties had originally presented on appeal, that there was sufficient evidence of imminent harm to the student. The Supreme Court reversed, holding (1) a properly instructed jury could reasonably conclude that Defendant’s conduct had subjected an identifiable person to imminent harm; and (2) because the jury was not instructed that it was required to make this finding, a new trial was required. View "Haynes v. City of Middletown" on Justia Law

Plaintiff, the named Defendant in this action, and others formed a limited liability company (the LLC) to purchase and redevelop certain property. After the LLC acquired the property, Plaintiff guaranteed the payment of two loans from a Bank. In the meantime, Plaintiff, Defendant, and others entered into backstop guarantee agreements that provided protection to Plaintiff in the event he was required to honor his personal guarantees to the Bank. The Bank later commenced foreclosure proceedings against the LLC and Plaintiff as guarantor. The court rendered a judgment of strict foreclosure, and the Bank sought a deficiency judgment against the Plaintiff. The Bank and Plaintiff entered into a settlement agreement. Thereafter, Plaintiff commenced the present action against Defendants to enforce the backstop guarantee agreements. The trial court concluded that the backstop guarantee agreements were unenforceable. The Appellate Court reversed. Defendant appealed, claiming that Plaintiff’s tax treatment of the debt that Defendant guaranteed effectively divested Plaintiff of his interest in the debt, and therefore, Plaintiff had no standing to enforce the backstop guarantee agreement. The Supreme Court affirmed, holding that Plaintiff had standing to enforce the agreement. View "One Country, LLC v. Johnson" on Justia Law

Defendant borrowed $143,065 in two separate loans from a Corporation. The Corporation assigned its interest in the notes to a Bank, which assigned the second loan (loan two) to Plaintiff, a municipality. Defendant had fully paid off the first loan (loan one), but determining that Defendant had defaulted on his payment obligations as to loan two, Plaintiff brought an action against Defendant to foreclose on the property. Defendant counterclaimed, arguing, among other things, that he made an overpayment on loan two. The trial court concluded that Plaintiff was liable to Defendant for the total amount Defendant claimed to have overpaid on loan two to Plaintiff and all other prior holders of the note. The Appellate Court reversed, concluding that, in the absence of an express contract provision, “an assignee generally does not assume the original responsibilities of the assignor." The Supreme Court affirmed, holding that the Appellate Court properly determined that Plaintiff, “as the most recent assignee and current holder of Defendant’s note, could not be held liable to repay Defendant for sums that were overpaid on the note before it was assigned to Plaintiff.” View "Hartford v. McKeever" on Justia Law

After a jury trial, Defendant was convicted of criminal possession of a firearm. Defendant appealed, arguing that the trial court erred in denying his motion to suppress evidence obtained by law enforcement officers as a result of their warrantless entry into a bedroom where he was sleeping. The Appellate Court reversed, concluding that it was unreasonable for the police to assume that Defendant was present in the bedroom and posed an imminent threat of harm to the apartment’s occupants. The Supreme Court reversed, holding that, under the totality of the circumstances, the police officers reasonably believed that the warrantless entry into the bedroom was necessary to protect their own safety and the safety of others on the premises, and therefore, the entry did not violate Defendant’s Fourth Amendment rights. View "State v. Kendrick" on Justia Law

Susan and Rodney Drown filed a medical malpractice action against Associated Women’s Health Specialists, P.C. (Health Specialists) asserting vicarious liability claims arising from the acts or omissions of its physicians. During the relevant period, Health Specialists was insured through a professional liability policy issued by Medical Inter-Insurance Exchange (Exchange). Health Specialists settled for the full amount of the policy and assigned to the Drowns its rights to recover against Exchange. Health Specialists was subsequently declared insolvent, and the Connecticut Insurance Guaranty Association (Association) assumed liability for the Exchange’s obligations. The Association then commenced this declaratory judgment action seeking a declaration that it had no obligations for the Drowns’ claims. Defendants, the Drowns and Health Specialists, counterclaimed. The trial court granted summary judgment in favor of Defendants. The Appellate Court reversed. The Supreme Court affirmed, holding (1) the Exchange’s preinsolvency breach of its duty to defend Health Specialists did not estop the Association from challenging its liability under the policy; and (2) the policy unambiguously did not cover Health Specialists for its vicarious liability in this case. View "Conn. Ins. Guar. Ass’n v. Drown" on Justia Law

After a jury trial, Defendant was found guilty of accessory to assault in the first degree by means of a dangerous weapon. Defendant appealed, arguing that the trial court abused its discretion in denying his motion to suppress the victim’s out-of-court and in-court identifications of him as one of the victim’s assailants. The Appellate Court reversed, concluding that the admission of Defendant’s identifications following an unnecessarily suggestive procedure by the police violated Defendant’s constitutional rights, and the error was not harmless beyond a reasonable doubt. The Supreme Court reversed, holding (1) contrary to the Court’s holding in State v. Gordon, the improper admission of suggestive and unreliable identification is subject to harmless error analysis; and (2) assuming, without deciding, that the trial court erred in denying Defendant’s motion to suppress the victim’s identification testimony, the error was harmless. View "State v. Artis" on Justia Law