Justia Connecticut Supreme Court Opinion Summaries

In 2003, local districts established for the promotion of tourism were legislatively dissolved to make way for larger regional districts serving that same purpose. Plaintiff, a Massachusetts corporation, filed suit against one of the regional districts (Defendant) seeking to hold Defendant liable for damages under a contract that Plaintiff had executed with one of the local districts (Local District). The district court certified questions of law to the Supreme Court regarding the satisfaction of contingent liabilities of the legislatively dissolved local districts. The Supreme Court answered (1) Defendant is not the legal successor to the Local District, as the legislature did not intend to make the regional districts the legal successors to the local districts; and (2) if the Local District transferred any of its assets to another entity and Plaintiff can establish that the assets were fraudulently conveyed, that entity may be responsible for the Local District’s obligations to the extent of the value of the assets received. View "Single Source, Inc. v. Cent. Reg’l Tourism Dist., Inc." on Justia Law

At issue in this criminal case was whether Conn. Gen. Stat. 53a-151(a), which proscribes tampering with a witness, requires the intent to influence a witness’ conduct at an official proceeding. After a jury trial, Defendant was convicted of tampering with a witness. The Appellate Court affirmed. Defendant argued on appeal that section 53a-151(a) does not prohibit mere attempts to prevent an individual from speaking to the police. The Supreme Court affirmed Defendant’s conviction, holding (1) the statute requires the intent to affect a witness’ conduct at an official proceeding, but a jury may infer this intent from the defendant’s attempt to prevent an individual from giving a statement to the police; and (2) there was sufficient evidence in this case indicating that Defendant believed an official proceeding was about to be instituted and that he threatened an individual with the intent to induce her to withhold testimony at a criminal trial. View "State v. Ortiz" on Justia Law

At issue in this certified appeal was the extent of a law enforcement agency’s disclosure obligations under the Freedom of Information Act (Act) with respect to pending criminal investigations. In 1993, the Supreme Court decided Gifford v. Freedom of Information Commission, which held that the police’s disclosure obligations during a pending criminal investigation were governed by the statutory predecessor to Conn. Gen. Stat. 1-215, which required a law enforcement agency to release only police blotter information. The legislature subsequently enacted Public Acts 1994, No. 94-246, 13, which amended the statutory predecessor to section 1-215 to require broader disclosure. In the instant case, the Freedom of Information Commission (Commission) found that the Department of Public Safety (Department) violated the Act by failing to disclose certain records from a pending criminal case. The trial court sustained the Department’s administrative appeal, and the Appellate Court affirmed. The Supreme Court affirmed, holding the enactment of Public Act 94-246 did not legislatively overrule the Court’s conclusion in Gifford that, during pending criminal prosecutions, section 1-215 exclusively governs law enforcement agencies’ disclosure obligations under the Act. View "Comm’r of Pub. Safety v. Freedom of Info. Comm’n" on Justia Law

This action arose from a rear-end collision allegedly caused by Zabian Bailey. Plaintiff filed a complaint against Bailey for negligence and against Progressive Northern Insurance Company for underinsured motorist benefits. A jury returned a verdict in favor of Plaintiff. Progressive filed a motion to set aside the verdict and for judgment in accordance with the motion for a directed verdict, claiming that Plaintiff failed to present sufficient evidence for the jury to reasonably find or infer negligence and proximate cause. The trial court denied the motion. The appellate court reversed and remanded with direction to grant Progressive’s motion. The Supreme Court reversed, holding that the evidence in this case was sufficient for a jury reasonably to find or infer that it was more probable than not that Bailey was negligent and that his negligence caused the collision. Remanded. View "Rawls v. Progressive N. Ins. Co." on Justia Law

Defendant was arrested without a warrant and charged with several crimes. Defendant filed a motion to be released without bond because a probable cause finding had not been made within forty-eight hours of his arrest. The trial court denied Defendant's motion. The appellate court upheld the trial court's decision. The Supreme Court affirmed, holding that, under the specific facts of this case, any violation of Defendant's Fourth Amendment rights was de minimis where (1) Defendant was present in the courthouse awaiting arraignment, at which point probable cause findings are typically made, prior to the expiration of the forty-eight hour period; and (2) the trial court found probable case for Defendant's arrest less than two hours after expiration of the forty-eight hour time period.View "State v. Heredia" on Justia Law

Janine Cannizzaro (Plaintiff) was involved in an automobile accident with Stephan Marinyak that caused catastrophic injuries to Plaintiff. Shortly before the accident, Marinyak, who was working for Diane Mayo (Defendant) during the restoration of Defendant's home, had consumed alcohol on the work site before leaving the premises in his car. Plaintiff sued Defendant, alleging negligent supervision, negligent service of alcohol, and reckless service of alcohol. The trial court granted summary judgment for Defendant. The Supreme Court affirmed, holding that Defendant did not owe Plaintiff a duty of care where Defendant never served alcohol to Marinyak, had no knowledge that Marinyak was drinking while on her property, had instructed a supervisor that she did not want Marinyak drinking while on her property, and was not present on the day of the accident. View "Cannizzaro v. Marinyak" on Justia Law

Plaintiff, the former wife of Defendant, filed a postjudgment motion to open, on the basis of fraud, a 2001 judgment dissolving the parties’ marriage. Plaintiff claimed that Defendant had failed to disclose the existence of an accrued but unvested pension either on his financial affidavits or otherwise. The trial court denied the motion after finding that Defendant had orally disclosed the existence of the pension to Plaintiff during the parties’ marriage and during settlement negotiations. The Supreme Court reversed, holding that the trial court (1) improperly concluded that Defendant’s unvested pension, at the time of the dissolution judgment, was not distributable marital property under Conn. Gen. Stat. 46b-81; and (2) improperly excluded evidence of the pension’s value on the basis that the evidence was irrelevant, thus tainting the court’s findings regarding disclosure. Remanded. View "Reville v. Reville" on Justia Law

Plaintiff, Leslie Milliun's conservator, filed a negligence suit against Defendant hospital, alleging that, while in Defendant's care, Leslie suffered severe respiratory dysfunction which resulted in Leslie's severe brain injury. The trial court rendered summary judgment in favor of Defendant because Plaintiff failed to offer the requisite expert testimony to create an issue of material fact regarding Defendant's alleged negligence as the proximate cause of Leslie's injuries. The appellate court reversed, holding that the trial court erred in (1) refusing to admit certain medical records of Leslie's treating physicians as expert opinion on causation, and (2) concluding that its order granting Plaintiff's motion for the appointment of a commission so Leslie's out-of-state treating physicians could be deposed should be withdrawn because the physicians could not be compelled to offer expert opinion on causation. The Supreme Court affirmed, holding that the appellate court properly determined that the trial court abused its discretion in failing to admit certain statements contained within the medical records to establish a causal connection between Leslie's injuries and the alleged negligence.View "Milliun v. New Milford Hosp." on Justia Law

After a hearing, the Department of Children and Families substantiated allegations that Plaintiff, an elementary school teacher, emotionally abused one of his students and recommended that Plaintiff’s name be placed on the Department’s central registry of child abuse and neglect. The trial court affirmed, ruling that the ultimate finding of the administrative hearing officer was supported by substantial evidence. The Appellate Court reversed and ordered the Department to remove Plaintiff’s name from the central registry. The Supreme Court reversed, holding that the Appellate Court (1) failed properly to credit the factual findings and legal conclusions of the administrative hearing officer; and (2) improperly concluded that the definition of “abused” found in Conn. Gen. Stat. 46b-120(3) was void for vagueness as applied to the facts of this case. View "Frank v. Dep’t of Children & Families" on Justia Law

Defendant was convicted of multiple offenses and sentenced to a term of incarceration followed by sixteen years of special parole. Defendant filed a motion to correct an illegal sentence, arguing that the trial court illegally sentenced him to a sixteen year term of special parole when, in light of the crimes at issue, the maximum terms of special parole was ten years. The trial court denied the motion. The appellate court reversed, concluding that the two consecutive sentences of special parole at issue - neither of which exceeded ten years individually but together imposed a total effective sentence of sixteen years of special parole - violated Conn. Gen. Stat. 54-125e(c), which operates as an aggregate limitation on the total effective sentence of special parole when a defendant is sentenced for multiple offenses. The Supreme Court reversed, holding that the ten year limitation on a period of special parole provided for in section 54-125e(c) applies per offense, rather than to the total effective sentence of special parole. Remanded. View "State v. Brown" on Justia Law