Justia Connecticut Supreme Court Opinion Summaries

Fanetta Arnold agreed to provide a guarantee in lieu of cash to satisfy the security deposit for an apartment for rent owned by Defendants, the Forvils. When Arnold attempted to move into the apartment on the agreed-upon date, Defendants prevented Arnold from taking possession because the security deposit had not been paid in cash. The Commission on Human Rights brought this action against Defendant on Arnold's behalf, alleging discrimination against Arnold based on her lawful source of income in violation of Conn. Gen. Stat. 46a-64c. The trial court found in favor of the Commission. The Supreme Court affirmed, holding, inter alia, that (1) because the judgment was rendered in a timely manner, the trial court properly exercised personal jurisdiction over Defendants; and (2) a security deposit guarantee is a lawful source of income within the meaning of the housing discrimination statutes. View "Comm'n on Human Rights & Opportunities ex rel. Arnold v. Forvil" on Justia Law

Plaintiff, landowner of property consisting in part of wetland soil, filed a petition for a declaratory ruling with the Fairfield town conservation commission, seeking a determination that certain activities, including the construction of roads, were permitted as of right pursuant to section 4.1(a) of the town's inland wetlands and watercourses regulations. The commission, acting it its capacity as the town's inland wetlands and watercourses agency, denied the petition. The trial court dismissed Plaintiff's administrative appeal. The Supreme Court affirmed, holding that the trial court properly determined that Conn. Gen. Stat. 22a-40(a)(1) and section 4.1(a) of the regulations did not permit, as of right, the filling of wetlands to construct roads, irrespective of whether the roads are directly related to the farming operation. View " Taylor v. Conservation Comm'n" on Justia Law

After a jury trial, Harry Gonzalez was convicted of felony murder, robbery in the first degree, and kidnapping in the first degree. On appeal, the Supreme Court reversed the judgment of the trial court, holding (1) the trial court improperly denied in part Gonzalez's motion to suppress certain statements he had made to the police because he made those statements as a result of police interrogation while in custody and without having been informed of his Miranda rights, and the error was not harmless beyond a reasonable doubt; and (2) Gonzalez's constitutional right against double jeopardy was not violated by his convictions of and separate punishments for felony murder and first degree robbery. Remanded for a new trial. View "State v. Gonzalez" on Justia Law

After a jury trial, Defendant was convicted of two counts of kidnapping in the second degree and one count of risk of injury to a child. The Supreme Court reversed the judgment of the trial court as to one of the two kidnapping counts and remanded for a new trial on that charge, holding (1) Defendant was entitled to a jury instruction in accordance with State v. Salamon, which bars a jury from finding a defendant guilty of kidnapping if it finds that the restraint used in connection therewith was merely incidental to the restraint used in the commission of another offense, and (2) the trial court's failure to give such an instruction was not harmless beyond a reasonable doubt. The Supreme Court affirmed the trial court's judgment in all other respects. View "State v. Fields" on Justia Law

Employee was diagnosed with silicosis, a condition caused by work with Employer, and filed a claim for workers' compensation benefits. During the course of Employee's employment, Employer's workers' compensation liability was covered by two insurers, first Liberty Mutual and, later, American Mutual. After Employee terminated his employment, American Mutual was declared insolvent. The Connecticut Guarantee Association subsequently became liable for certain American Mutual obligations. The workers' compensation commissioner held the association initially liable for payment of benefits as the last insurer on the risk. The workers' compensation review board affirmed. The association appealed, contending that deeming the association liable conflicted with the requirement under the Connecticut Insurance Guaranty Association Act that other insurance policies covering the same claim must be exhausted before recovery is permitted from the association. The Supreme Court affirmed, concluding that holding the association liable for an insolvent insurer's obligation as the last insurer on the risk does not conflict with the Guaranty Act. View "Franklin v. Superior Casting" on Justia Law

Letitia Kilby filed a complaint with the Commission on Human Rights and Opportunities, claiming unlawful housing discrimination by Defendants, the town housing authority and a property management company. The Commission found reasonable cause to believe that unlawful discrimination occurred. The trial court then granted Defendants' request to file a civil action in the trial court. Kilby moved to intervene, claiming both intervention as of right and permissive intervention. The trial court denied the motion. The appellate court reversed, concluding that although the statute at issue, Conn. Gen. Stat. 46a-83(d)(2), did not expressly grant Kilby a right of intervention, it impliedly granted Kilby a right of intervention. The Supreme Court granted Defendants' petition for certification to appeal, but while the case was pending, the legislature enacted Conn. Pub. Acts 11-237, which amended the text of section 46a-83 to allow a complainant to intervene as of right in a housing discrimination action brought by the commission on behalf of the complainant. The Court dismissed the appeal, concluding that the significance of Defendants' appeal was substantially undermined by Conn. Pub. Acts 11-237, and, thus, certification was improvidently granted. View "Comm'n on Human Rights & Opportunities v. Litchfield Housing Auth." on Justia Law

After a jury trial, defendant Oles Baptiste was convicted of assault of a peace officer and interfering with an officer. Defendant appealed, claiming that the trial court's jury instructions on the charges deprived him of his right to a fair trial and to present a defense. The appellate court affirmed, concluding that Defendant waived any constitutional or plain error claim by not raising an objection in the lower court proceedings. On appeal, Defendant claimed that the appellate court erred in concluding that he waived his claim of instructional error under State v. Kitchens, asserting that he did not have a meaningful opportunity for review of the jury instructions because the trial court held only a brief charging conference and Defendant did not receive a written copy of the instructions. The Supreme Court reversed the judgment of the appellate court, holding that because Defendant did not have a meaningful opportunity to review the charges, Defendant's claim was not implicitly waived under Kitchens. Remanded. View "State v. Baptiste" on Justia Law

After a police officer received frantic telephone calls by a concerned parent about his missing teenage son and the parent suggested that his son might be at the home of defendant Gary Ryder, the officer conducted a warrantless search of Ryder's home. During the search, the officer found a large reptile in Ryder's tub. Ryder was charged with risk of injury to a child and illegal possession of a reptile. The State entered a nolle prosequi with regard to the first charge, and Ryder entered a plea of nolo contendere to the possession of a reptile charge, later paying a fine. Ryder appealed from the trial court's denial of his motions to suppress and to dismiss the charges. Ultimately, the appellate court affirmed, concluding that the emergency exception to the warrant requirement justified the officer's entry into Ryder's home. On appeal, the Supreme Court reversed the judgment of the appellate court, holding that the emergency exception to the warrant requirement did not justify the warrantless search of Ryder's curtilage and the subsequent warrantless search of Ryder's home. Remanded. View "State v. Ryder" on Justia Law

After a jury trial, Defendant Thomas W. was convicted of risk of injury to a child and sexual assault in the fourth degree. On appeal, Defendant contended that the trial court improperly diluted the State's burden of proof and placed the burden of proof on Defendant by instructing the jurors that they must decide whether Defendant was "innocent or guilty" of the crimes for which he was charged. The appellate court declined to review Defendant's claim on the ground of waiver, concluding that Defendant waived his claim of instructional error. The Supreme Court granted certification. At issue was whether Defendant could be deemed to have waived his objection to certain language in the final instructions to the jury when, after a charging conference and other procedures consistent with the standard set forth in State v. Kitchens, Defendant did not object to that language but previously had objected to essentially the same language in the trial court's preliminary instructions to the jury. The Supreme Court affirmed the appellate court's judgment, holding that, under the facts of the case, Defendant waived his claim under the general rule enunciated in Kitchens. View "State v. Thomas W." on Justia Law

Defendant Patrick Lenarz was charged with risk of injury to a child and sexual assault in the fourth degree. Before trial, the prosecutor came into possession of and read certain written materials belonging to Defendant that contained trial strategy and were subject to the attorney-client privilege. Upon learning this fact, Defendant filed a motion to dismiss the charges against him. The trial court denied the motion. After a trial, the trial court convicted Defendant of one count of risk of injury to a child. Defendant appealed, claiming that the trial court improperly denied his motion to dismiss. The Supreme Court reversed, holding that because the case was irreversibly tainted by the prosecutor's intrusion into the privileged communications, the only available appropriate remedy was dismissal of the charge of which he was convicted. The Court concluded that when a prosecutor has intruded into privileged communications containing a defendant's trial strategy and the state has failed to rebut the presumption of prejudice, the court, sua sponte, must immediately provide appropriate relief to prevent prejudice to the defendant. Remanded. View "State v. Lenarz" on Justia Law