Justia Connecticut Supreme Court Opinion Summaries

The case involves the State of Connecticut and the Connecticut State University Organization of Administrative Faculty, AFSCME, Council 4, Local 2836, AFL-CIO. The plaintiff, the state, sought to vacate an arbitration award reinstating a union member to his employment as the director of student conduct at a state university. The defendant union sought to confirm the award. The grievant’s employment had been terminated in connection with a domestic dispute involving his wife. The university conducted its own investigation and subsequently informed the grievant that his employment was being terminated as a result of his off-duty conduct. The union contested the grievant’s discharge, and an arbitration hearing was held. The arbitrator concluded that the university did not have just cause to terminate the grievant’s employment and ordered his reinstatement.The state contended that the award violated public policy. The trial court rendered judgment granting the state’s application to vacate the award and denying the union’s motion to confirm the award, from which the union appealed. The Supreme Court of Connecticut held that the state failed to demonstrate that enforcement of the arbitration award reinstating the grievant to his position of director of student conduct violated public policy. The court reversed the trial court’s judgment and remanded the case with direction to grant the union’s motion to confirm the award and to deny the state’s application to vacate the award. View "State v. Connecticut State University Organization of Administrative Faculty" on Justia Law

The plaintiff, Deutsche Bank AG, sought to recover damages from the defendants, Alexander Vik and his daughter, Caroline Vik, for their alleged interference with a business expectancy. The plaintiff was attempting to collect an approximately $243 million foreign judgment from a company, Sebastian Holdings, Inc. (SHI), which the plaintiff claimed was controlled by Alexander. The plaintiff alleged that the defendants had attempted to interfere with a Norwegian court’s order requiring the sale of SHI’s shares in a Norwegian software company, Confirmit, to partially satisfy the foreign judgment. The defendants filed a motion to dismiss the action for lack of subject matter jurisdiction, arguing that the plaintiff’s claims were barred by the litigation privilege because they were based on communications made and actions taken in prior judicial proceedings. The trial court denied the motion to dismiss, and the defendants appealed to the Appellate Court, which reversed the trial court’s decision and remanded with direction to dismiss the plaintiff’s complaint in its entirety.The Supreme Court of Connecticut reversed the Appellate Court’s judgment and remanded with direction to affirm the trial court’s denial of the defendants’ motion to dismiss. The Supreme Court held that the defendants could not prevail on their claim that the plaintiff’s appeal was rendered moot by virtue of the court’s decision in a previous case. The court also held that the Appellate Court incorrectly determined that the plaintiff’s claims against the defendants were barred by the litigation privilege. The court concluded that many of the tactics Alexander allegedly used to disrupt, delay, and otherwise interfere with the sale of Confirmit, including stacking Confirmit’s board of directors with family members and associates, submitting a disingenuous bid to acquire Confirmit, coordinating with his father to have the plaintiff’s execution lien deregistered, and forging and backdating the document purporting to grant Caroline a right of first refusal, occurred outside of the context of any judicial proceeding and, therefore, were not covered by the litigation privilege. View "Deutsche Bank AG v. Vik" on Justia Law

In this case, two candidates for state legislative offices in the 2014 general election, Joe Markley and Rob Sampson, were fined by the State Elections Enforcement Commission for violating state statutes and regulations governing campaign financing. The candidates' campaign committees had received public funding grants and published communications that criticized the then-governor, who was running for reelection. The commission found that the candidates had violated the applicable statutes and regulations by using their campaign funds to pay for communications that criticized the governor while promoting their opposition to his policies.The candidates appealed to the trial court, arguing that the statutes and regulations violated their First Amendment rights by restricting their ability to speak about other, non-opposing candidates. The trial court upheld the commission's decision, agreeing that the candidates had violated the statutes and regulations and concluding that the restrictions did not infringe on the candidates' First Amendment rights.On appeal to the Supreme Court of Connecticut, the candidates argued that the commission's enforcement of the statutes and regulations violated their First Amendment rights. The court held that the commission's enforcement of the statutes and regulations imposed an unconstitutional condition in violation of the First Amendment. The court found that the commission's enforcement of the statutes and regulations penalized the candidates for mentioning the governor's name in a manner that was not the functional equivalent of speech squarely directed at his reelection campaign. The court reversed the trial court's judgment and remanded the case with direction to sustain the candidates' administrative appeal. View "Markley v. State Elections Enforcement Commission" on Justia Law

The case involves Northland Investment Corporation (N Co.), a landlord of multiunit residential buildings, and the Public Utilities Regulatory Authority (PURA). N Co. sought a declaratory ruling from PURA that it could use ratio utility billing (RUB) to recoup utility costs from tenants in buildings without individual meters. Under RUB, N Co. would bill tenants for their proportionate share of utility usage, calculated based on factors like unit square footage and number of occupants. PURA concluded that RUB violated the statute because it prohibited charging a tenant for utilities they did not exclusively use. However, PURA suggested N Co. could use the "building in" methodology, incorporating estimated utility costs into fixed rent.PURA's decision was appealed to the trial court, which remanded the case back to PURA for further consideration of whether its decision on RUB conflicted with its conclusion on the "building in" approach. PURA reaffirmed its prior ruling, and N Co. appealed again to the trial court, which dismissed the appeal. N Co. then appealed from the trial court's judgment.The Supreme Court of Connecticut upheld the trial court's decision, agreeing with PURA's determination that the statute prohibits N Co.'s proposed use of RUB to recoup building-wide utility costs by billing tenants for their estimated proportionate share of the total cost. The court concluded that the "building in" approach was acceptable as it allowed for consistent and predictable payments each month and placed the risk of higher-than-anticipated utility usage on the landlord. View "Northland Investment Corp. v. Public Utilities Regulatory Authority" on Justia Law

The case involves a dispute between a bank and a homeowner over a foreclosure action. The bank sought to foreclose on a mortgage after the homeowner defaulted on a promissory note secured by the mortgage. The mortgage agreement included a provision authorizing the bank to purchase force placed insurance coverage for the property if the homeowner failed to maintain adequate coverage. The homeowner alleged that the bank was involved in an undisclosed kickback scheme with an insurance provider, which led to him being charged more than the cost of purchasing the force placed coverage, contrary to the provisions of the mortgage agreement and certain representations the bank had made to him. The bank filed a motion to strike the special defenses and the counterclaim, which the trial court granted in part. The trial court subsequently granted the bank’s motion for summary judgment as to liability and rendered judgment of foreclosure by sale, from which the homeowner appealed.The Supreme Court of Connecticut denied the bank's motion to dismiss the appeal, concluding that the filed rate doctrine, as applied by the federal courts, did not affect the court’s subject matter jurisdiction over this appeal. The court also found that the trial court improperly struck the homeowner’s special defenses of unclean hands and breach of the implied covenant of good faith and fair dealing. The court reasoned that the homeowner's allegations were directly related to the bank's enforcement of the provision of the mortgage agreement authorizing the bank to purchase force placed insurance, and the alleged effect of the bank’s conduct in enforcing that provision, that it wrongfully increased the homeowner’s overall debt, provided a sufficient nexus to the foreclosure action. The court reversed the trial court’s judgment and remanded the case for further proceedings. View "M&T Bank v. Lewis" on Justia Law

The case revolves around a dispute over workers' compensation benefits. The plaintiff, an employee of Frank Lill & Son, Inc., claimed to have sustained two separate injuries during his employment. He sent a written notice of claim to his employer and the Workers’ Compensation Commission. The employer, within twenty-eight days of receiving the plaintiff’s notice of claims, mailed a notice of intention to contest the plaintiff’s right to compensation benefits. However, the administrative law judge did not receive the notice of intention until after the twenty-eight day statutory period had elapsed. The plaintiff then filed a motion to preclude the defendants from contesting liability, arguing that the employer had failed to commence payment of the claims or to file a notice of intention to contest the claims within the required timeframe.The administrative law judge granted the plaintiff’s motion, concluding that the employer had failed to meet the requirements of the statute, and therefore, the defendants were presumed to have accepted the compensability of the plaintiff’s alleged injuries and were precluded from contesting his claims. The Compensation Review Board upheld the administrative law judge’s decision.The case was then brought before the Connecticut Supreme Court. The defendants argued that they had met their statutory obligation by mailing the notice within the statutory period, and that "mailing" should be considered the same as "filing" for the purposes of the statute. However, the court disagreed, stating that the statutory language was clear that the notice of intention to contest must be delivered, not just mailed, to the administrative law judge within the specified timeframe. The court also noted that the use of different terms in the same statute suggested that the legislature intended for the terms to have different meanings. The court affirmed the decision of the Compensation Review Board, ruling that the employer had not met its statutory obligation. View "Ajdini v. Frank Lill & Son, Inc." on Justia Law

The case revolves around a dispute over visitation rights for a minor child, L. The plaintiff, Laurie Hepburn, is the sister of L's deceased mother and had lived with L since her birth in 2010. After the death of L's mother in 2021, L's father, the defendant Chandler Brill, took L to live with him full-time. Hepburn filed a petition for visitation rights, which Brill moved to dismiss for lack of subject matter jurisdiction, arguing that Hepburn lacked standing under the third-party visitation statute because she failed to allege sufficient facts to establish that she had a parent-like relationship with L and that L would suffer real and significant harm if visitation were denied.The trial court granted the defendant's motion to dismiss the initial petition, concluding that it did not satisfy the requirements of the third-party visitation statute. The court also dismissed, on its own, the amended petition, concluding that its allegations, if proven by clear and convincing evidence, would not establish the plaintiff’s parent-like relationship with L or establish that L would suffer real and significant harm if visitation were to be denied.The Supreme Court of Connecticut reversed the trial court's judgment, holding that the trial court improperly dismissed the plaintiff’s amended petition for visitation with L. The court found that the plaintiff had adequately alleged both the existence of a parent-like relationship and that the denial of visitation would cause L real and significant harm. The case was remanded for further proceedings. View "Hepburn v. Brill" on Justia Law

The case involves a dispute between Mercedes-Benz Financial and 1188 Stratford Avenue, LLC, and its principal, Aniello Dizenzo. The plaintiff, Mercedes-Benz Financial, alleged that the defendants breached a motor vehicle lease agreement by failing to make payments. After the defendants failed to appear, the trial court granted the plaintiff's motion for judgment and rendered a default judgment in favor of the plaintiff. The defendants later moved to open and set aside the default judgment, arguing that the vehicle had serious defects, making it dangerous to operate, and that they had returned the vehicle to the dealership. They also claimed that they mistakenly thought the case had been resolved.The trial court denied the defendants' motion to open the judgment, concluding that the motion was untimely and had no basis. The defendants appealed to the Appellate Court, which acknowledged that the trial court incorrectly determined that the motion was untimely but upheld the trial court's decision, concluding that it had not abused its discretion in denying the motion on the ground that it had no basis.The defendants then appealed to the Connecticut Supreme Court. The Supreme Court held that the Appellate Court incorrectly concluded that the trial court had not abused its discretion in denying the defendants’ motion to open. The Supreme Court found that the trial court's determination that the motion was untimely was incorrect, and this error likely affected the trial court's decision on the merits of the motion. The Supreme Court reversed the Appellate Court’s judgment and remanded the case for further proceedings, directing the lower court to reverse its judgment and conduct an evidentiary hearing on the defendants' motion to open the judgment. View "Mercedes-Benz Financial v. 1188 Stratford Avenue, LLC" on Justia Law

The case revolves around a plaintiff who was arrested for operating a motor vehicle while under the influence of intoxicating liquor. The arresting officer prepared a report of the incident and mailed it to the Department of Motor Vehicles (DMV), but not within the three business days required by statute. At the plaintiff's license suspension hearing, the plaintiff's attorney objected to the admission of the report on the grounds that it was not prepared and mailed within the statutory timeframe. The hearing officer overruled the objection and admitted the report, which was the only evidence submitted at the hearing.The trial court dismissed the plaintiff's appeal, concluding that strict adherence to the preparation and mailing requirement was not necessary for the report to be admissible. The Appellate Court affirmed the trial court's judgment, concluding that the preparation and mailing requirement is directory, and therefore, strict compliance with that requirement is not necessary for a report to be admissible at a license suspension hearing.The Supreme Court of Connecticut reversed the Appellate Court's judgment. The court held that the hearing officer abused her discretion in admitting an incident report that did not strictly comply with the preparation and mailing provision of the statute in the absence of testimony from the arresting officer. The court concluded that the preparation and mailing requirement was mandatory because it promoted the accuracy and reliability of the information that would be used at a license suspension hearing. The court clarified that the statute describes substantive requirements that incident reports must meet, and the failure to meet those requirements renders a report inadmissible insofar as it fails to satisfy the exception for the report to be admitted without the need to produce the arresting officer at the suspension hearing. View "Marshall v. Commissioner of Motor Vehicles" on Justia Law

The defendant, Gonzalo Diaz, was convicted of felony murder, burglary in the first degree, conspiracy to commit burglary in the first degree, attempt to commit robbery in the first degree, and criminal possession of a firearm in connection with a shooting death. The defendant appealed, claiming that the trial court committed plain error by instructing the jury that it could consider his interest in the outcome of the trial when assessing his credibility. He also claimed that the prosecutor made improper remarks during his cross-examination and during rebuttal argument.The Superior Court in the judicial district of Waterbury found Diaz guilty of felony murder, manslaughter in the first degree with a firearm, burglary in the first degree, conspiracy to commit burglary in the first degree, and attempt to commit robbery in the first degree. The court also found him guilty of criminal possession of a firearm. The court later vacated the conviction for manslaughter in the first degree with a firearm.The Connecticut Supreme Court affirmed the lower court's decision. The court agreed that the trial court's instruction to the jury was erroneous, but it did not result in manifest injustice. The court also found that the prosecutor's remarks were not improper. The court concluded that the defendant failed to establish that the evidence adduced at trial, the disputed factual issues before the jury, and the instructions as a whole gave rise to the danger of juror misunderstanding or confusion. Therefore, the court affirmed the judgment of the trial court. View "State v. Diaz" on Justia Law