Justia Connecticut Supreme Court Opinion Summaries

Defendant was charged with, inter alia, six counts of capital felony in connection with a triple murder, sexual assault, and arson. During the trial, the trial court granted the motion of intervenors, a newspaper and one of its reporters, to vacate an order sealing Defendant's "witness list." The appellate court dismissed Defendant's appeal of the trial court decision for lack of a final judgment. The Supreme Court granted Defendant's petition for certification to appeal, (1) concluding that the appeal should be treated as a late petition for certification to appeal and, therefore, not determining whether the appellate court properly concluded the trial court's decision was not a final judgment; and (2) reversing the trial court's order granting the intervenors' motion to vacate the sealing order, holding that Defendant demonstrated that the potential abridgement of his rights to a fair trial and to prepare a defense clearly outweighed the rights of the intervenors and the public to access the witness list document. View "State v. Komisarjevsky" on Justia Law

After Defendant was charged in three criminal cases and, in a fourth case, with violating his probation, he was found incompetent to stand trial and not restorable to competency. Defendant filed a motion to dismiss the charges in all four cases, claiming (1) he was entitled to dismissal of two cases involving misdemeanor charges and the violation of probation case because the statute of limitations had expired, and (2) he was entitled to dismissal of the case involving a felony charge pursuant to Practice Book 41-8. The trial court granted the motion to dismiss with respect to all four of the pending cases on the ground that it lacked personal jurisdiction over Defendant. The Supreme Court (1) affirmed the trial court's judgment dismissing the two cases involving misdemeanor charges on the alternate ground that the charges were subject to dismissal pursuant to section 54-56d(m) because the statute of limitations had expired; (2) reversed the judgment of dismissal as to the felony charge and remanded for a determination as to whether the case should be dismissed pursuant to Practice Book 41-8(5); and (3) dismissed the portion of the appeal regarding the dismissal of the violation of the probation case. View "State v. Johnson" on Justia Law

At age fifteen, Defendant was charged with larceny in the second and fourth degrees and burglary in the third degree. Before the juvenile court, the State filed a motion to transfer the charges from the juvenile docket to the regular criminal docket pursuant to Conn. Gen. Stat. 46b-127(b). The juvenile court denied the State's motion. After the State filed an appeal, the Supreme Court released its decision in State v. Fernandes, which interpreted section 46b-127(b) to comply with due process requirements because, prior to the finalization of the transfer of a case involving certain crimes from the juvenile docket to the regular criminal docket, the juvenile is entitled to a hearing in the criminal court to contest the appropriateness of trying the juvenile as an adult. On appeal, the Supreme Court reversed the juvenile court's denial of the State's motion to transfer the charges of larceny in the second degree and burglary in the third degree and affirmed in all other respects, holding (1) Fernandes controlled in this case, and (2) before the transfer of Defendant's case to the regular criminal docket was finalized, Defendant was entitled to a hearing before the court on the regular criminal docket. Remanded. View "State v. Elias G." on Justia Law

Defendant was charged and convicted of murder, carrying a pistol without a permit, and criminal possession of a pistol. At trial, three witnesses who had criminal matters pending in a variety of venues testified that they had seen Defendant commit the murder. On appeal, Defendant claimed (1) the trial court committed plain error when it failed to instruct the jury, sua sponte, that the testimony of the three witnesses should be viewed with great caution in light of potential benefits the witnesses could receive from the government in their pending criminal matters in exchange for their testimony; and (2) in the alternative, the Supreme Court should exercise its supervisory power to require such an instruction. The Supreme Court affirmed the judgment of conviction, holding (1) the trial court did not commit plain error when it failed to give, sua sponte, a special credibility instruction for the three witnesses; and (2) because trial courts already have discretion to give a special credibility instruction under existing case law whenever the court reasonably believes a witness' testimony may be particularly unreliable, there is no need for the Court to create a new supervisory rule requiring a special credibility instruction in such cases. View "State v. Diaz" on Justia Law

Plaintiffs, the administrators of Decedent's estate, brought a medical malpractice action against Defendants, a thoracic surgeon and the surgeon's employer. Plaintiffs attached to their original complaint an opinion letter from a physician who was board certified in internal medicine with a subspecialty in cardiovascular disease. Plaintiffs subsequently filed an amended complaint. Defendants moved to dismiss Plaintiffs' original complaint on the grounds that Plaintiffs failed to comply with the requirements of filing a medical malpractice lawsuit mandated by Conn. Gen. Stat. 52-109a(a) as a result of their failure to attach to their complaint an opinion letter from a similar health care provider. The trial court granted the motion. The Supreme Court reversed, concluding that Defendants waived their right to challenge the sufficiency of the original complaint and its attachment by failing to timely file a motion to dismiss. Remanded. View "Morgan v. Hartford Hosp." on Justia Law

Plaintiff, Metropolitan Property and Casualty Insurance Company, brought a product liability action against Defendant, Deere and Company, claiming that a lawn tractor manufactured by Defendant contained a manufacturing defect in its electrical system that caused a fire resulting in the destruction of the home of Plaintiff's insureds. Following a jury trial, the trial court rendered judgment in favor of Plaintiff. The Supreme Court reversed, holding (1) a plaintiff may base a product liability action on the "malfunction theory," which allows a jury to rely on circumstantial evidence to infer that a product that malfunctioned was defective at the time it left the manufacturer's or seller's control if the plaintiff establishes certain elements; and (2) the trial court erred in denying Defendant's motion for a directed verdict because Plaintiff's evidence in the present case was insufficient to establish its products liability claim. View "Metro. Prop. & Cas. Ins. Co. v. Deere & Co." on Justia Law

Plaintiff, the commissioner of labor, applied to the superior court for a warrant to inspect the premises of Defendant, a fire company, to investigate whether the fire company was in compliance with the requirements of Connecticut's Occupational Safety and Health Act. The trial court dismissed for lack of subject matter jurisdiction the commissioner's warrant application, concluding that the fire company did not fall within the act's definition of a covered employer, which by statutory definition was "the state and any political subdivision thereof" because the fire company was an independent corporation. The Supreme Court affirmed, holding that the fire company did not fall within the core definition of a political subdivision of the state. View "Mayfield v. Goshen Volunteer Fire Co." on Justia Law

Plaintiffs, John and Colm Farrell, were allegedly involved in a motor vehicle accident with an insured of Defendant, Twenty-First Century Insurance Company. Plaintiffs filed an action against Defendant, seeking damages for personal injuries arising out of the accident. During a pretrial conference, the parties agreed to settle Plaintiffs' claims and, allegedly, further agreed to arbitrate Plaintiffs' claims. Subsequently, Plaintiffs filed an action against Defendant seeking a court order to compel arbitration. The trial court rendered summary judgment in favor of Defendant, concluding that there was no clear manifestation of an agreement to arbitrate. The appellate court affirmed. The Supreme Court affirmed the judgment of the appellate court, holding that, after drawing all inferences in favor of Plaintiffs, no genuine issue of material fact existed with regard to whether the parties had an enforceable agreement to arbitrate. View "Farrell v. Twenty-First Century Ins. Co." on Justia Law

Plaintiff, employee, brought an action against Defendants, an archdiocese and a parish pastor, claiming that their refusal to renew her contract for employment as the principal of the parish school constituted, inter alia, wrongful termination in violation of public policy, breach of implied contract and breach of promissory estoppel. The trial court denied Defendants' motion to dismiss the action on the ground that adjudication of Plaintiff's claims called for impermissible judicial interference in the internal governance of the archdiocese with respect to its selection of religious leaders. At issue on appeal was whether the ministerial exception to judicial authority that precludes a court from adjudicating certain religious disputes required dismissal of the action. The Supreme Court first determined it had subject matter jurisdiction over the interlocutory appeal, and then reversed the trial court, holding that (1) in considering whether the ministerial exception is applicable in a particular case, a Connecticut state court must follow the Rweyemamu v. Cote standard; and (2) the ministerial exception applied to the various claims in the plaintiff's complaint. Remanded with direction to dismiss Plaintiff's complaint. View "Dayner v. Archdiocese of Hartford" on Justia Law

Complainant, an attorney and private investigator, asked the town tax assessor to provide him with an exact electronic copy of the file that the department of motor vehicles had provided to the town pursuant to Conn. Gen. Stat. 14-163 for use in preparing the town's motor vehicle grand list. The assessor denied the request, stating that the electronic file was protected from disclosure pursuant to Conn. Gen. Stat. 1-217. The freedom of information commission ordered the town to provide to complainant an exact electronic copy of the electronic file. Several parties intervened as plaintiffs, and the trial court consolidated their administrative appeals. The court then dismissed the appeals. The Supreme Court reversed the trial court, holding that section 1-217 applies to motor vehicle grand lists and their component data provided to the town assessors pursuant to section 14-163. View "Comm'r of Pub. Safety v. Freedom of Info. Comm'n" on Justia Law