Justia Connecticut Supreme Court Opinion Summaries

Two days before his eighteenth birthday, Petitioner filed a petition seeking to have himself adjudicated as neglected and as an uncared-for youth. The trial court dismissed the petition as moot because, two days after Petitioner filed it, he reached his eighteenth birthday. The appellate court affirmed, concluding that the trial court lacked subject matter jurisdiction over the neglect petition. The Supreme Court affirmed but on an alternate ground, holding that the trial court lacks statutory authority to adjudicate a person neglected or uncare-for pursuant to Conn. Gen. Stat. 46b-129(a) after the person reaches the age of eighteen years, and, therefore, the court necessarily lacks statutory authority to provide dispositional relief to such a person pursuant to Conn. Gen. Stat. 46b-129(j). View "In re Jose B." on Justia Law

When she was seventeen years old, Petitioner filed a petition alleging that she was a neglected and uncared for youth. The trial court dismissed the petition as moot because, two and one-half months after Petitioner filed it, she reached her eighteenth birthday. The appellate court affirmed. The Supreme Court affirmed, holding (1) the trial court lacked statutory authority both to adjudicate Petitioner neglected or uncared-for after she reached the age of eighteen years and to provide her with dispositional relief; and (2) because the court lacked such statutory authority, that court properly concluded that the petition was rendered moot when Petitioner reached her eighteenth birthday. View "In re Jessica M." on Justia Law

After a jury trial, Defendant Leotis Payne was convicted of, inter alia, felony murder, robbery in the first degree, and attempt to tamper with a juror. The Supreme Court affirmed, holding (1) the trial court improperly joined for trial the felony murder and jury tampering cases against the Defendant for trial, but the error was harmless; (2) the trial court improperly admitted the testimony of one of the state's witnesses regarding an alleged threat made by Defendant, but the error was harmless; and (3) three statements by the prosecutor during closing and rebuttal arguments were improper, but those improprieties did not deprive Defendant of a fair trial, and therefore, Defendant was not entitled to a new trial due to the prosecutorial improprieties. In affirming the judgments of the trial court, the Court also overruled State v. King and its progeny, which recognized a presumption in favor of joinder in criminal cases. View "State v. Payne" on Justia Law

Defendant Osibisa Hall pleaded guilty to one count of possession of marijuana with intent to sell and two counts of violation of a protective order. Defendant subsequently filed a motion to withdraw his guilty pleas and vacate the judgments of conviction, claiming that the trial court did not fulfill its obligation to address him personally and determine that he understood the immigration consequences of his pleas. The court denied the motion. The appellate court reversed, finding that the trial court failed to comply substantially with Conn. Gen. Stat. 54-1j when it neglected to personally address Defendant regarding the potential immigration consequences of his pleas. The Supreme Court reversed the appellate court, holding (1) substantial compliance with section 54-1j can be established even if the court does not address the defendant personally; and (2) the trial court substantially complied with section 54-1j in the present case. View "State v. Hall" on Justia Law

In an underlying employment dispute, Employee sued Employer for discrimination. After the jury issued a verdict in favor of Defendant, Plaintiff moved for a new trial, alleging that Defendant had engaged in discovery misconduct. The trial court denied Plaintiff's motion. The appellate court affirmed. At issue before the Supreme Court was whether a party seeking a new trial on the basis of alleged knowing and deliberate discovery misconduct must show that the result at a new trial would likely be different. The Supreme Court affirmed, holding that the rule set forth in Varley v. Varley to determine whether a new trial should be granted on the basis of allegations that the judgment was obtained through fraud, as reframed in this decision, applies to motions for a new trial based on the discovery misconduct of the nonmoving party. View "Duart v. Dep't of Corr." on Justia Law

At issue in this appeal was whether nonunion Plaintiffs, Electrical Contractors, Inc. (ECI) and six of its employees had standing to challenge prebid specifications requiring the successful bidder on two state financed construction projects to perform all project work with union labor under the terms of a project labor agreement. The trial court dismissed Plaintiffs' complaint for lack of standing. The Supreme Court reversed the trial court's dismissal of the claims of ECI against the city and other nonstate defendants, and affirmed the court's dismissal of ECI's claims against several state defendants, holding (1) the individual plaintiffs did not have standing to bring their claims; (2) ECI had standing to bring its claims against the nonstate defendants, as it had a colorable claim of injury; (3) ECI had standing to bring its claim against the city for violation of the Connecticut Antitrust Act; (4) Plaintiffs' claims were not preempted by federal labor law; and (5) Plaintiffs failed to allege facts that reasonably supported their claims against the state defendants, and therefore, the trial court's judgment could be affirmed on the alternative ground that Plaintiffs' claims against the state defendants were barred by the doctrine of sovereign immunity. View "Elec. Contractors, Inc. v. Dep't of Educ." on Justia Law

After a jury trial, Defendant Darryl W. was convicted of criminal attempt to commit aggravated sexual assault in the first degree, sexual assault in the third degree and kidnapping in the first degree with a firearm. The trial court also found Defendant guilty of violation of probation based on his conviction of the criminal offenses. The Supreme Court affirmed the judgments of the trial court, holding (1) Defendant failed to preserve his claims that the court improperly instructed the jury regarding the elements of aggravated sexual assault in the first degree and kidnapping in the first degree with a firearm and regarding his affirmative defense to kidnapping in the first degree with a firearm; and (2) certain comments by the senior assistant state's attorney during closing argument did not constitute prosecutorial impropriety. View "State v. Darryl W." on Justia Law

After a jury trial, Defendant Herman Apodaca was convicted of felony murder, conspiracy to commit robbery in the first degree, and robbery in the first degree. The Supreme Court affirmed, holding (1) trial court properly dismissed a juror midtrial for cause; (2) the trial court properly instructed the juror on the felony murder count; (3) under the facts of the case, the court did not violate its obligations by declining to rephrase the entire conspiracy instruction in laypersons' terms after the jury requested further instructions; and (4) the trial court's instructions on conspiracy to commit robbery were not misleading, and therefore, Defendant's due process rights were not violated by the instructions. View "State v. Apodaca" on Justia Law

Defendant Alia Altajir pleaded nolo contendere to charges of misconduct with a motor vehicle. The trial court imposed a sentence of five years' incarceration, suspended after one year, and five years of probation. Defendant later violated the special conditions of her probation. At a subsequent dispositional hearing, the trial court admitted undated photographs gathered from Facebook, on which Defendant maintained a profile. Defendant appealed, arguing that the trial court had violated her right to due process by admitting the photographs. The appellate court determined that this claim was unpreserved and did not merit review. The Supreme Court affirmed on the ground that the photographs satisfied the minimum standard of reliability constitutionally required to admit evidence at the dispositional phase of a probation revocation hearing. View "State v. Altajir" on Justia Law

The named plaintiff in the underlying action, Ernest Francis, brought a declaratory judgment action against all members of the Connecticut General Assembly. Francis received a waiver of the process server's service fees, including a fee for copies, pursuant to Conn. Gen. Stat. 52-261(a)(2). The plaintiff in error, state marshal Lisa Stevenson (Plaintiff), effectuated service on all defendants. Francis' son had made the copies of the complaint at his expense. Plaintiff subsequently submitted an invoice claiming fees of, inter alia, $900 for copies of the complaint. The trial court disallowed the fee for copies. At issue before the Supreme Court was whether section 52-261(a)(2) entitles a process server to the fee for copies even if she has not personally made the copies. The Court concluded that the trial court, the defendant in error, improperly denied Plaintiff's request for fees where (1) the statute was ambiguous, and (2) clear evidence of legislative intent proved that the fee for copies under section 52-261(a)(2) was not contingent upon the process server's making the copies. View "Francis v. Fonfara" on Justia Law