Justia Connecticut Supreme Court Opinion Summaries

The Supreme Court reversed the judgment of the appellate court in this action to recover damages for Defendants' alleged medical malpractice affirming the trial court's judgment granting Defendants' motion to dismiss, holding that the Supreme Court incorrectly concluded in Morgan v. Hartford Hospital, 21 A.3d 451 (Conn. 2011), that the opinion letter requirement implicates the court's personal jurisdiction for purposes of the procedures attendant to a motion to dismiss.On appeal, Plaintiff argued that the appellate court incorrectly concluded that the trial court should not have considered an affidavit filed by Plaintiff to supplement a potentially defective opinion letter as an alternative to amending the operative complaint. The Supreme Court reversed, holding (1) the opinion letter requirement is a unique, statutory procedural device that does not implicate the superior court's jurisdiction; (2) the sufficiency of the opinion letter is to be determined solely on the basis of the allegations in the complaint and on the face of the opinion letter, without resorting to a jurisdictional fact-finding process; and (3) the opinion letter at issue in this case was legally sufficient under Conn. Gen. Stat. 52-190a. View "Carpenter v. Daar" on Justia Law

The Supreme Court affirmed the decision of the trial court granting summary judgment in favor of Insurer in this action brought to determine whether business losses suffered during the COVID-19 pandemic were covered by the relevant policies, holding that Insured's losses were not covered by the two insurance policies at issue.Before the pandemic, Insurer sold two insurance policies to Insured. Insurer later initiated this action seeking a judgment declaring that Insured's business losses incurred during the COVID-19 pandemic were not covered under the policies. The trial court concluded that there was no coverage under either policy. The Supreme Court affirmed, holding that the trial court properly entered summary judgment for Insurer because Insured's losses plainly and unambiguously were not covered by either policy. View "Hartford Fire Insurance Co. v. Moda, LLC" on Justia Law

The Supreme Court affirmed the judgment of the trial court in this dispute over whether a property insurance policy providing coverage for "direct physical loss of or physical damage to" covered property provided coverage for business income losses arising from the suspension of business operations during the COVID-19 pandemic, holding that the trial court correctly granted Defendant's motion for summary judgment.Plaintiffs, who suspended their business operations during the COVID-19 pandemic and consequently lost business income and incurred other expenses, filed claims for losses with Defendants. After Defendants denied the claims Plaintiffs brought this actin seeking a judgment declaring that the relevant insurance policies covered their economic losses under the circumstances. The trial court granted summary judgment for Defendants. The Supreme Court affirmed, holding that because Plaintiffs did not suffer any "direct physical loss" of covered property, there was no genuine issue of material fact as to whether the policies did not cover Plaintiffs' claims. View "Connecticut Dermatology Group, PC v. Twin City Fire Insurance Co." on Justia Law

The Supreme Court dismissed this appeal stemming from the COVID-19 pandemic and the controversy over whether a mandate should be implemented requiring the state's schoolchildren to wear masks while in school, holding that this Court lacked jurisdiction.In June 2020, the state Department of Education, the state Commissioner of Education, and the Governor (collectively, Defendants) undertook to mandate that schoolchildren wear masks in school. Plaintiffs brought this lawsuit challenging the legality of Defendants' school mask mandate and seeking declaratory and injunctive relief. The Supreme Court granted summary judgment for Defendant, concluding that Plaintiffs were not entitled to relief. Plaintiffs appealed. The Supreme Court dismissed the appeal, holding that because the Department repealed the school mask mandate while this appeal was pending, the appeal was moot. View "Conn. Freedom Alliance, LLC v. Dep't of Education" on Justia Law

The Supreme Court reversed in part the decision of the appellate court affirming the order of the trial court rendering summary judgment in favor of Defendants in a tort action on the grounds that the claims were barred by the doctrine of collateral estoppel, holding that no preclusion doctrine barred Plaintiff from litigating her tortious interference with contractual relations claim.Plaintiff alleged that Defendants tortiously interfered with her contractual relations and right of inheritance by exercising undue influence over her husband, the decent, with respect to a proposed amendment to an antenuptial agreement and a testamentary will. The trial court entered summary judgment for Defendants, ruling that the doctrine of collateral estoppel barred both of Plaintiff's tortious interference claims. The appellate court affirmed. The Supreme Court reversed in part, holding (1) under the circumstances of this case, Plaintiff's claim for tortious interference with contractual relations was not precluded; and (2) Plaintiff was collaterally estopped from relitigating her tortious interference with a right of inheritance claim. View "Solon v. Slater" on Justia Law

The Supreme Court affirmed the judgment of the trial court denying Defendant's motion to suppress statements he had made during two separately recorded interrogations of him by police officers, holding that the trial court properly denied Defendant's motion to suppress.The two interrogations at issue occurred on the same day. As to the first interrogation, Defendant claimed that the police failed to advise him of his rights pursuant to Miranda v. Arizona, 384 U.S. 436 (1966). Defendant further claimed that the second interrogation was tainted by the alleged illegality of the first interrogation. The trial court denied the motion to suppress and, following a jury trial, convicted Defendant of manslaughter in the first degree with a firearm. The Supreme Court affirmed, holding (1) Miranda warnings were not required for the first interrogation because it was not custodial; and (2) the failure to provide the warnings did not taint the second interrogation. View "State v. Brandon" on Justia Law

The Supreme Court affirmed the judgment of the habeas court denying Petitioner's petition for a writ of habeas corpus, holding that Petitioner failed to establish that he was entitled to relief.Petitioner was convicted of manslaughter in the first degree with a firearm, assault in the first degree, and criminal possession of a firearm. In his habeas petition, Petitioner argued that his trial counsel's concession of Petitioner's guilt to the manslaughter charge without Petitioner's prior approval violated his rights to effective assistance of counsel under Strickland v. Washington, 466 U.S. 668 (1984), and personal autonomy under McCoy v. Louisiana, __ U.S. __ (2018). The habeas court denied the petition, finding Petitioner's claims to be without merit. The Supreme Court affirmed, holding (1) the habeas court correctly determined that Petitioner's right to autonomy was not implicated under the facts of this case; and (2) Petitioner's second claim on appeal was unpreserved. View "Grant v. Commissioner of Correction" on Justia Law

The Supreme Court reversed the judgment of the appellate court affirming the decision of the trial court to deny Defendant's motion to open the judgment and vacated the trial court's judgment of foreclosure by sale in favor of Plaintiff, The Bank of New York Mellon, holding that the appellate court erred.The trial court concluded that Defendant's motion to open constituted a collateral attack on an earlier judgment. Defendant appealed, arguing that Plaintiff lacked standing to pursue foreclosure, and thus, the trial court lacked jurisdiction over the action. The appellate court disagreed, concluding that Defendant's motion to open constituted an impermissible collateral attack on the foreclosure judgment. The Supreme Court reversed and remanded the case, holding that the appellate court (1) erroneously concluded that Defendant's motion to open was a collateral attack because, at the time Defendant filed his motion to open, the trial court had jurisdiction to open the judgment under Neb. Rev. Stat. 52-212a; and (2) this Court rejects the alternative ground that the trial court properly denied Defendant's motion to open in which he claimed that the trial court lacked subject matter jurisdiction. View "Bank of New York Mellon v. Tope" on Justia Law

The Supreme Court affirmed the judgment of the trial court joining for trial, pursuant to Practice Book 41-19, sexual assault, risk of injury to a child, and strangulation charges with threatening and disorderly conduct charges, holding that the trial court did not err or abuse its discretion.Specifically, the Supreme Court held that the trial court did not abuse its discretion when it (1) joined the sexual assault cases and the threatening and disorderly conduct cases for trial; and (2) denied Defendant's request, as a remedy for the disclosure of his prior incarceration by one of the state’s witnesses, that he be allowed to testify about the nonsexual nature of his prior felony convictions without opening the door to being asked on cross-examination about the nature of those convictions. View "State v. James A." on Justia Law

The Supreme Court reversed in part the judgment of the appellate court affirming Defendant's conviction of sexual assault in the first degree, risk of injury to a child, and conspiracy to commit risk of injury to a child, holding that the case must be remanded to the trial court for a new trial on the sexual assault count.On appeal from his convictions, Defendant argued that each count was duplicitous because each count charged him with a single violation of the underlying statute when the evidence established multiple, separate incidents of conduct and, consequently, the court's failure to either grant his request for a bill of particulars or a specific unanimity instruction violated his constitutional right to jury unanimity. The Supreme Court reversed in part, holding (1) count two, charging the defendant with a single violation of Conn. Stat. Ann. § 53-21 (a) (2), was not duplicitous, and thus the trial court’s failure to grant the defendant’s request for a specific unanimity instruction or a bill of particulars as to that count did not violate his constitutional right to jury unanimity; and (2) Defendant was not entitled to reversal of his remaining convictions. View "State v. Joseph V." on Justia Law