Justia Connecticut Supreme Court Opinion Summaries

Plaintiffs, two unions, filed a petition for a declaratory ruling with the Department of Public Utility Control seeking a ruling establishing that the Department had violated the Uniform Administrative Procedure Act by failing to promulgate regulations prescribing the rights of persons designated as participants in uncontested proceedings before the Department. The Department denied Plaintiffs’ petition. The trial court set aside the Department’s decision, concluding that the Department was required to promulgate the regulations. The Supreme Court reversed, holding that the trial court lacked jurisdiction over Plaintiffs’ appeal because Plaintiffs did not plead sufficient facts that, if true, demonstated that they were aggrieved by the Department’s ruling on their petition. Remanded with direction to dismiss Plaintiffs’ appeal. View "Conn. Indep. Util. Workers, Local 12924 v. Dep’t of Pub. Util. Control" on Justia Law

After a jury trial, Defendant was convicted of sexual assault in a spousal relationship in violation of Conn. Gen. Stat. 53a-70b. Defendant appealed, claiming that the trial court should interpret section 53a-70b to require proof beyond a reasonable doubt that Defendant acted with the specific intent to commit the crime of sexual assault in a spousal relationship. The appellate court rejected the claim and affirmed. The Supreme Court affirmed, holding that the appellate court properly concluded that section 53a-70b requires that Defendant had only a general intent to commit the act that constituted a violation of the statute.View "State v. Ferdinand R." on Justia Law

After a jury trial, Petitioner was convicted of several offenses in connection with an incident involving Petitioner’s estranged girlfriend. Petitioner later filed a second amended petition for a writ of habeas corpus, claiming that his trial counsel provided ineffective assistance. Specifically, Petitioner alleged that his counsel’s criminal prosecution shortly before Petitioner’s criminal trial constituted a conflict of interest. The habeas court denied Petitioner’s petition. The appellate court affirmed, concluding that Petitioner’s claim failed on the merits. At issue before the Supreme Court was whether there was a constitutionally impermissible risk that a jury would attribute the conduct of Petitioner’s trial counsel to Petitioner when his counsel had been acquitted of a dissimilar crime in the same judicial district in which Petitioner faced criminal prosecution. The Supreme Court affirmed, holding that Petitioner failed to demonstrate an actual conflict of interest that adversely affected his trial counsel’s performance. View "Rodriguez v. Comm’r of Corr." on Justia Law

Mother, who resided in Connecticut, and Father, who resided in Florida, were divorced pursuant to a decree that awarded primary physical custody of the parties' child to Mother and ordered Father to pay alimony and child support. Father later filed a motion to modify the alimony and child support order, alleging that his relocation from Florida to Connecticut in order to be closer to his son resulted in his decreased income, which constituted a substantial change in circumstances. The trial court denied Defendant's motion, and the appellate court affirmed. The Supreme Court reversed, holding (1) in deciding whether to grant a motion for modification, a court must first determine whether the moving party has established a substantial change in circumstances, and in making this determination, if a party's voluntary action gives rise to the alleged substantial change in circumstances, the court must assess the motivations underlying the voluntary conduct in order to determine whether there is culpable conduct foreclosing a threshold determination of a substantial change in circumstances; and (2) the trial court in this case improperly denied Father's motion for modification solely on the basis that Father's voluntary relocation gave rise to the alleged substantial change in circumstances warranting modification. Remanded.View "Olson v. Mohammadu" on Justia Law

Plaintiff sued Defendant, alleging that Defendant aided and abetted Plaintiff’s former attorneys in breaching their fiduciary duties to Plaintiff and that Defendant’s actions violated the Connecticut Unfair Trade Practices Act. The trial court entered summary judgment for Defendant, concluding that Plaintiff’s claims were barred by the applicable three year statutes of limitations and that tolling was inapplicable. The Supreme Court affirmed, holding (1) Plaintiff sufficiently invoked the continuing course of conduct doctrine before the trial court; but (2) equitable tolling pursuant to the continuing course of conduct doctrine was not available under the facts of this case. View "Flannery v. Singer Asset Fin. Co., LLC" on Justia Law

Plaintiff filed a breach of contract action against Defendant, her insurer, claiming that Defendant improperly denied her claim for homeowners' insurance coverage after a fire damaged her home. BSI Financial Services, Inc., as the holder of the note and mortgage on Plaintiff's home, sought to intervene in the underlying action. The trial court denied the motion to intervene as untimely based on the policy's one year limitation period. The Supreme Court reversed, holding (1) the trial court erred in denying the motion to intervene without first determining whether the motion related back to the original complaint; and (2) the motion to intervene did not constitute a new, separate action but, rather, related back to Plaintiff's original complaint. Remanded.View "Austin-Cesares v. Safeco Ins. Co. of Am." on Justia Law

While working for Employer, Employee filed notice of a workers' compensation claim related to a lower back injury he received during the course of his employment. Employee was discharged approximately four years later pursuant to a termination agreement that provided that he agreed to release Employer from any and all workers' compensation claims. Employer later brought an action against Employee, alleging civil theft, fraud, unjust enrichment, and conversion based on Defendant's admission that he never intended to release his workers' compensation claim. Employee counterclaimed, claiming that Employer's cause of action was in retaliation for Employee's decision to exercise his rights under the Workers' Compensation Act. Employer filed a motion to dismiss the counterclaim, asserting that the doctrine of absolute immunity shielded Employer from the counterclaim. The trial court denied the motion. The Supreme Court affirmed the trial court's decision denying Plaintiff's motion to dismiss, holding that an employer's right to seek redress for its alleged grievances in court does not outweigh an employee's interest in exercising his rights under the Act without fear of retaliation by his employer, and therefore, absolute immunity did not shield Employer from Employee's counterclaim.View "MacDermid, Inc. v. Leonetti" on Justia Law

Petitioner was charged with various criminal offenses in two informations. After a jury trial, Petitioner was convicted of sexual assault in the second degree, assault in the second and third degrees, and risk of injury to a child. After the convictions were affirmed on appeal, Petitioner filed a petition for a writ of habeas corpus, alleging ineffective assistance of counsel. The habeas court found Petitioner's pretrial counsel had rendered ineffective assistance by failing to provide Petitioner with adequate advice regarding a pretrial plea offer and ordered the trial court to resentence Petitioner in accordance with the sentence proposed in the plea offer. The appellate court affirmed. The Supreme Court reversed, holding that the habeas court improperly circumvented the trial court's discretion to impose an appropriate sentence. Remanded.View "H.P.T. v. Comm'r of Corr." on Justia Law

Defendant was charged with murder, among other crimes. Defendant, who was indigent, waived his right to appointed counsel and elected to represent himself. Defendant requested that the trial court order funding so that he could retain experts and an investigator in order to present a defense. The parties subsequently entered into a joint stipulation requesting the trial court to reserve questions of law to the Supreme Court regarding the funding issue. The Supreme Court answered (1) an indigent self-represented defendant is constitutionally entitled to expert or investigative services at public expense, provided that he makes a threshold showing that such assistance is reasonably necessary to formulate and present a defense; (2) the trial court does not retain the discretion to authorize public expenditures for any such expert witness or investigator; and (3) the public funds should come from the State’s Office of the Chief Public Defender. View "State v. Wang" on Justia Law

While intoxicated, Plaintiff stumbled and fell into a bonfire and suffered serious burns. Plaintiff brought an action for negligence and recklessness against Defendant, alleging that Defendant was negligent and reckless in allowing Plaintiff, who was underage, to drink alcohol at Defendant’s home to the point of intoxication and to attend the bonfire while intoxicated. The trial court entered judgment in favor of Defendant. Plaintiff appealed, arguing that the trial court erred in instructing the jury on contributory negligence because the doctrine was not a legally recognized defense for a claim involving service of alcohol to minors. The Supreme Court affirmed, holding that the trial court properly instructed the jury to consider whether the negligence of Plaintiff materially contributed to cause his injuries. View "Stafford v. Roadway" on Justia Law