Justia Connecticut Supreme Court Opinion Summaries

The local board of education of the City of Bridgeport passed a resolution requesting the state board of education to authorize the commissioner of education to reconstitute the local board. The state board voted to authorize the commissioner to reconstitute the local board. In three separate actions, former local board members and residents and electors of the City filed actions against the state board, local board, and others, alleging state statutory and constitutional violations. The trial court reserved the action for the advice of the Supreme Court. At issue was (1) whether the failure of the state board to require the local board to undergo and complete training, as mandated by Conn. Gen. Stat. 10-223e(h), rendered void the state board's authorization; and (2) whether the local board's resolution requesting that the state board authorize reconstitution resulted in a waiver of the state board's obligation to require training. The Supreme Court concluded (1) the state board's failure to require training rendered void its authorization of reconstitution under section 10-223e(h); and (2) the local board's resolution had no effect on the operation of the statute. View "Pereira v. State Bd. of Educ." on Justia Law

A jury found Defendant guilty of four drug-related crimes. The appellate court concluded that there was insufficient evidence to support Defendant's conviction of possession of narcotics with intent to sell within 1500 feet of a school in violation of Conn. Gen. Stat. 21a-278a(b) and possession of drug paraphernalia with intent to use within 1500 feet of a school in violation of Conn. Gen. Stat. 21a-267(c) and remanded the case, directing the trial court to render judgment of not guilty on these charges. The Supreme Court affirmed in part and reversed in part, holding that the appellate court (1) properly held that there was insufficient evidence to support Defendant's conviction under section 21a-278a(b), but (2) improperly held that there was insufficient evidence to support Defendant's conviction under section 21a-267(c). Remanded for a new trial on the charge of possession of drug paraphernalia with the intent to use within 1500 feet of a school. View "State v. Lewis" on Justia Law

The freedom of information commission ordered the University of Connecticut to disclose databases identifying persons who had paid to attend, donated to, inquired about or participated in certain educational, cultural or athletic activities of institutions within the university. The trial court sustained the university's appeal, concluding that the university could, as a matter of law, create a trade secret entitled to exemption from disclosure under the Freedom of Information Act. The commission appealed, contending that, in light of the public policy favoring disclosure of public records, the trial court improperly rejected the commission's determination that none of the databases at issue could be trade secrets because the university was not principally involved in a trade. The Supreme Court affirmed, holding that a public agency can create and maintain trade secrets that are exempt from disclosure under the Act, as long as the information meets the statutory criteria for a trade secret. View "Univ. of Conn. v. Freedom of Info. Comm'n " on Justia Law

Plaintiff, the former town clerk of the town of Watertown, was removed from her position after she failed to report for work. Plaintiff subsequently filed a complaint against the town and certain of its officials (1) seeking a writ of mandamus ordering Defendants to restore her salary and benefits from the time they were discontinued and to continue such payments for the duration of her term, (2) claiming Defendants had violated her constitutional rights pursuant to 42 U.S.C. 1983, and (3) seeking recovery of her lost salary. The trial court granted Plaintiff's motion for partial summary judgment on counts one and three. The court, however, rendered judgment in favor of defendants on count two of the complaint based upon the jury's finding that there had not been a constitutional violation of due process. The Supreme Court reversed the judgment in part and remanded the case for further proceedings on counts one and three, holding that the trial court improperly concluded that Plaintiff had a clear legal right to be paid for the balance of her elected term unless or until she was removed from office. View "Stewart v. Watertown" on Justia Law

Two houseguests suffered serious injuries after their host left her car running overnight in an attached garage and the house filled with carbon monoxide. Plaintiff, the insurer with whom the homeowner had a homeowner's insurance policy, brought a declaratory judgment action against Defendants, the homeowner, the houseguests, and the homeowner's automobile insurer, seeking a declaration that the homeowner's policy did not cover the injuries suffered by the houseguests. The trial court granted summary judgment in favor of Plaintiff, finding that the policy did not cover the injuries because they fell within the policy exclusion for injuries arising out of the use of a motor vehicle. The Supreme Court affirmed, holding that the injuries suffered by the houseguests fell under the policy's motor vehicle exclusion. View "New London County Mutual Ins. Co. v. Nantes" on Justia Law

Plaintiffs, the town of Bozrah and the town's zoning enforcement officer, brought an action seeking a temporary and permanent injunction to enjoin Defendants, owners and residents of certain property, from refusing to consent to an inspection of their property for zoning violations. The trial court granted a temporary injunction preventing Defendants from refusing to allow the inspection, concluding that pursuant to Camara v. Municipal Court, the reasonable governmental interest in stabilizing property values and promoting the general welfare justified an inspection in the present action. Defendants appealed, claiming that the trial court's order violated their right to be free from unreasonable searches and seizures. The Supreme Court reversed, holding (1) a zoning official may inspect a single property pursuant to Conn. Gen. Stat. 8-12 if the official first obtains an injunction issued upon probable cause by a judicial officer; and (2) because the trial court failed to make a preliminary determination of probable cause to believe that a zoning violation existed on the property, its order permitting a search of Defendants' property violated the Fourth Amendment. Remanded. View "Bozrah v. Chmurynski" on Justia Law

Plaintiffs, Kristy and Timothy Wilcox, brought a medical malpractice action against Defendants, a general surgeon (Doctor) and his employer, alleging that Doctor negligently performed laparoscopic gallbladder surgery on Kristy. The trial court granted Defendants' motion to dismiss, concluding that the written opinion of a similar health care provider that accompanied the certificate of good faith, as mandated by Conn. Gen. Stat. 52-190a(a), did not satisfy the "detailed basis" requirement of the statute because it failed to explain the particular manner in which Doctor had breached the standard of care. The appellate court reversed. The Supreme Court affirmed, holding (1) a written opinion satisfies the "detailed basis" requirement of section 52-190a(a) if it states the similar health care provider's opinion as to the applicable standard of care, the fact that the standard of care was breached, and the factual basis of the similar health care provider's conclusion concerning the breach of the standard of care; and (2) the written opinion in the present case was sufficiently detailed to satisfy section 52-190a(a). View "Wilcox v. Schwartz" on Justia Law

Plaintiff divorced his wife (Wife) after discovering she had had an extramarital affair with Defendant and had conceived a child (Child) with him. After Plaintiff and Wife divorced, Plaintiff brought an action against Defendant, seeking damages on claims of nondisclosure, misrepresentation, and unjust enrichment. Specifically, Plaintiff sought reimbursement from Defendant for the costs he had expended in raising Child from her birth until his divorce from Wife, when Child was almost fifteen years old. The trial court concluded that although Defendant was Child's biological father, the doctrine of equitable estoppel and public policy concerns precluded Plaintiff from pursuing his claims for reimbursement and denying his paternity. The Supreme Court reversed the judgment of the trial court, holding that the court improperly found that Plaintiff was equitably estopped from pursuing his claims because there was insufficient evidence of financial harm to Child, which is required to establish the element of detrimental reliance in a case involving a denial of paternity. View "Fischer v. Zollino" on Justia Law

This case concerned the distribution of surplus proceeds from a foreclosure sale of property encumbered by multiple successive mortgages obtained through fraud. Defendant Stewart Title Guaranty Company appealed from the judgment of the trial court rendered in favor of Defendant First American Title Insurance Company and ordering that the remaining proceeds of a foreclosure sale be distributed to First American. The Supreme Court affirmed, holding (1) the trial court properly granted First American's motion to intervene in the action, (2) the trial court applied a proper standard of review in granting relief pursuant to First American's motion to reargue the trial court's decision determining the priorities of the parties; and (3) the trial court's conclusion that First American was entitled to receive all of the remaining funds from the foreclosure sale could be upheld on the alternate ground that, because First American's mortgage was recorded prior in time to Stewart Title's mortgage, it was entitled to all of the surplus proceeds on deposit pursuant to the first in time, first in right rule. View "Hudson Valley Bank v. Kissel" on Justia Law

Defendant Rafael Crespo was convicted of one count of assault in the third degree and two counts of sexual assault in the first degree. Defendant's conviction stemmed from allegations that he had forcibly engaged in sexual intercourse with the victim and physically assaulted her on several occasions during their relationship. The appellate court affirmed. After analyzing the case under State v. Golding the Supreme Court affirmed, holding that the trial court properly excluded impeachment evidence regarding the victim's prior sexual conduct and that the exclusion of this evidence did not clearly violate Defendant's constitutional rights to confrontation and to present a defense. View "State v. Crespo" on Justia Law