Justia Connecticut Supreme Court Opinion Summaries

Plaintiff, administratrix of the estate of the decedent, brought a defective highway action under Conn. Gen. Stat. 13a-144 against the Department of Transportation alleging that a truck lost control as it traveled down Avon Mountain along Route 44, resulting in the death of the decedent. Defendant filed a motion to dismiss the action on the ground that Plaintiff’s allegations were insufficient to state a claim under section 13a-144, claiming that the allegations did not fall within the limited exception to the general rule barring design defect claims under the defective highway statute. The trial court denied Defendant’s motion. The Appellate Court reversed, concluding that Plaintiff failed to allege an actionable highway defect under section 13a-144. The Supreme Court affirmed, holding that the Appellate Court properly determined that Plaintiff’s complaint failed to state a claim under section 13a-144, as the plan of design providing for the steep downhill grade, together with the absence of tangible safety measures, as implemented, did not create an otherwise actionable highway defect as defined by case law. View "Stotler v. Dep’t of Transp." on Justia Law

Plaintiff brought a defective highway action under Conn. Gen. Stat. 13a-144 against the Department of Transportation alleging that he sustained severe injuries when a truck descending Avon Mountain along Route 44 experienced brake failure and collided with multiple vehicles, including Plaintiff’s. Defendant filed a motion to dismiss the action on the ground that Plaintiff failed to state a claim under section 13a-144, and therefore, the action was barred by sovereign immunity. Specifically, Defendant asserted that the allegations did not fall within the limited exception to the general rule barring design defect claims under the defective highway statute. The trial court denied the motion. The Appellate Court reversed, concluding that Plaintiff’s complaint failed to state a cause of action under section 13a-144. The Supreme Court affirmed, holding that Plaintiff’s claim was barred by sovereign immunity because it did not fall within the ambit of the defective highway statute. View "Cummings v. Dep’t of Transp." on Justia Law

Respondent was charged as a juvenile with several firearms-related offenses. The State filed a motion seeking a discretionary transfer of Respondent’s case to the regular criminal docket of the superior court pursuant to Conn. Gen. Stat. 46b-127(b)(1). The trial court granted the State’s motion. Respondent appealed. The Appellate Court dismissed the appeal for lack of a final judgment. The Supreme Court affirmed, holding that the a transfer order made pursuant to the discretionary transfer provision in section 46b-127(b)(1) is not a final judgment for purposes of appeal, as the clear intent of the Legislature is to prohibit interlocutory appeals from discretionary transfer orders. View "In re Tyriq T." on Justia Law

After a jury trial, Defendant was convicted of murder, two counts of kidnapping in the second degree, and assault in the third degree. Defendant appealed, arguing that the trial court abused its discretion in joining his two cases for trial and that the evidence was insufficient was support his conviction of both counts of kidnapping in the second degree. The Supreme Court affirmed in part and reversed in part, holding (1) the trial court did not err in joining the two cases; (2) the evidence was sufficient to support the judgment of conviction of one count of second degree kidnapping and the assault conviction; but (3) the jury could not reasonably have found that two separate instances of kidnapping occurred. Remanded with direction to render a judgment of acquittal on one count of kidnapping in the second degree. View "State v. Crenshaw" on Justia Law

Plaintiff brought a breach of contract action against Defendants. The trial court granted summary judgment in favor of Defendants, and the appellate court affirmed. Plaintiff appealed, arguing that the appellate court improperly upheld the trial court’s decision to grant Defendants’ motion for summary judgment on grounds not raised by Defendants. The Supreme Court affirmed, holding (1) a reviewing court has the discretion to raise and decide an issue that the parties themselves have not raised if (i) exceptional circumstances exist that would justify review of such an issue if raised by a party, (ii) the parties are given an opportunity to be heard on the issue, and (iii) no unfair prejudice to the party against whom the issue is to be decided results; (2) the appellate court in this case did not exceed its authority in resolving Plaintiff’s appeal on the basis of an issue that Defendants had not raised; and (3) the appellate court did not err in deciding the issue and in granting summary judgment to Defendants.View "Blumberg Assocs. Worldwide, Inc. v. Brown & Brown of Conn., Inc." on Justia Law

Defendant, the president of Moving America of CT, Inc., entered into a contract with Plaintiff, Yellow Book Sales and Distribution Company, Inc., on Moving America’s behalf. After Moving America dissolved, Plaintiff filed an action against Defendant in his individual capacity pursuant to an alleged individual guarantee in the contract, claiming that Defendant was individually liable to Plaintiff for the balance remaining unpaid on Moving America’s account. The trial court granted summary judgment in favor of Defendant, concluding that the contract was ambiguous as to whether Defendant was a party to the contract in his individual capacity, and therefore, the contract was unenforceable pursuant to the statute of frauds. The appellate court affirmed. The Supreme Court reversed, holding that the contract unambiguously identified Defendant as a party in his individual capacity and imposed a primary obligation, rather than a collateral one, on Defendant to provide full performance, thus rendering the statute of frauds inapplicable. Remanded. View "Yellow Book Sales & Distrib. Co., Inc. v. Valle" on Justia Law

Plaintiff and her employer (Defendant) signed a document regarding the terms of Plaintiff’s employment. The parties agreed the document would cover "a thirty-six month period." After Defendant terminated Plaintiff’s employment before the term expired, Plaintiff filed suit, alleging that she and Defendant had entered into a letter agreement for a fixed term of employment of thirty-six months and that Defendant violated the agreement. The trial court concluded that, on its face, the letter agreement constituted a contract for a definite term and that Defendant breached the agreement when it terminated Plaintiff’s employment without good cause before the term expired. The appellate court affirmed. The Supreme Court reversed, holding that the letter agreement was ambiguous. Specifically, the language of the letter agreement could reasonably be interpreted as evincing either an intent to create a definite term of employment or an intent to set the terms and conditions of an at-will employment contract, and therefore, the trial court should have considered extrinsic evidence to determine the intent of the parties. Remanded for a new trial. View "Cruz v. Visual Perceptions, LLC" on Justia Law

Plaintiff-school opened a bank account for its operating fund with Defendant-bank. One of Plaintiff’s employees later opened a bank account with Defendant that Plaintiff had not authorized and deposited into that account several hundred checks originating from, or intended to be deposited into, Plaintiff’s bank account with Defendant. Over the course of approximately four years, the employee deposited $832,776 into this bank account and withdrew funds just short of that amount. Defendant refused Plaintiff’s demand to return the funds that the employee had funneled through this account to himself. Thereafter, Plaintiff commenced this action, alleging breach of contract, violations of the Uniform Commercial Code (UCC), negligence, and common law conversion. The trial court rendered judgment in favor of Plaintiff on each of the counts and awarded $832,776 in total compensatory damages. The Supreme Court affirmed in all respects with the exception of the damages award, holding that some of Plaintiff’s claims under the UCC were time barred and that the trial court did not otherwise err in its judgment. Remanded with direction to reduce the award by $5,156 and to proportionately reduce prejudgment interest, . View "Saint Bernard Sch. of Montville, Inc. v. Bank of Am. " on Justia Law

In 1994, the State contracted with Lombardo Brothers Mason Contractors, Inc. to perform masonry for the construction of the library at the University of Connecticut School of Law. In 2008, the State sued Lombardo for faulty construction. From 1994 to 2008, several insurance carriers assumed Lombardo’s risk, including Travelers Casualty and Surety Company of America and Travelers Indemnity Company (together, Travelers) and The Netherlands Insurance Company (Netherlands). Netherlands refused to provide a defense, and Travelers spent more than $482,855 defending Lombardo. Travelers then filed a complaint against Netherlands and other insurers, seeking a judgment declaring that Netherlands was obligated to defend Lombardo and pay to Travelers its pro rata share of the costs incurred in defending Lombardo. The trial court granted judgment in favor of Travelers. Netherlands appealed, raising a number of appellate issues. The Supreme Court affirmed, holding that the trial court did not err in its judgment. View "Travelers Cas. & Surety Co. of Am. v. Netherlands Ins. Co." on Justia Law

After a jury trial, Defendant was convicted of murder and sentenced to fifty years imprisonment. Defendant appealed, contending that he had been deprived of a fair trial because of improper statements made by the prosecutor during trial and in closing argument. The Appellate Court affirmed the judgment of conviction, concluding that only certain statements by the prosecutor were improper, and Defendant was not deprived of a fair trial as a result. Defendant and the State separately appealed. The Supreme Court affirmed, holding (1) the State’s appeal must be dismissed because the State was not aggrieved by the judgment of the Appellate Court; and (2) Defendant was not deprived of a fair trial. View "State v. Albino" on Justia Law