Justia Connecticut Supreme Court Opinion Summaries

In this case regarding the "homestead act," Public Acts 1993, No. 93-301, 2 (P.A. 93-301), and involving a certified question in a bankruptcy appeal from the United States District Court for the District of Connecticut, the Supreme Court held that Public Acts 2021, No. 21-161, 1 (P.A. 21-161) applies in all bankruptcy proceedings filed on or after the effective date of the act to debts that accrued prior to that date.When the legislature enacted the act in 1993 a debtor could protect up to $75,000 of the value of a primary residence from attachment in postjudgment proceedings or bankruptcy, but the act included the following carve-out: the homestead exemption could not be claimed for debts accrued prior to the effective date. In 2021, the legislature amended the act by, among other things, increasing the exemption to $250,000. This time, however, the legislature did not include a special carve-out for a debtor's preexisting debts. At issue was whether the Supreme Court should read such a carve-out into P.A. 21-161. The Supreme Court answered the question in the negative and that P.A. 21-161, 1 was not retractive as applied to the debtor's bankruptcy petition in this case. View "In re Cole" on Justia Law

The Supreme Court reversed the judgment of the appellate court concluding that there was not substantial record evidence to support the determination of the presiding human rights referee's determination of intentional discrimination in this action challenging an employment termination decision, holding that the appellate court erred.The referee determined that the Hartford Police Department had discriminated against Hoa Phan, a probationary police officer on the basis of his Vietnamese and Asian ancestry by terminating his employment. The trial court affirmed. The appellate court reversed, ruling that the trial court erred in finding that substantial evidence supported the referee's finding of intentional discrimination. The Supreme Court reversed, holding (1) the referee correctly determined that Phan had established his prima facie case; and (2) the appellate court's alternative holding that substantial evidence did not support the referee's finding of intentional discrimination was erroneous. View "Hartford Police Dep't v. Commission on Human Rights & Opportunities" on Justia Law

The Supreme Court affirmed the judgment of the trial court terminating Father's parental rights as to his minor child (Child), holding that the trial court did not violate Father's right to adequate notice when it terminated Father's parental rights after the close of the evidence pursuant to Conn. Gen. Stat. 17-112(j)(3)(B)(ii).At the close of the evidence in this case the Commissioner of Children and Families moved to amend the petition to allege a different ground for the termination of Father's rights. The trial court granted the motion pursuant to Practice Book section 34a-1(d). Thereafter, the Commissioner of Children and Families filed an amended summary of the facts in support of its petition claiming that grounds existed for termination of Father's parental rights pursuant to section 17a-112(j)(3)(B)(ii). At the conclusion of trial, the trial court granted the petition to terminate Father's parental rights on ground (B)(ii). The Supreme Court affirmed, holding that the trial court did not violate Father's constitutional due process right to adequate notice by allowing the Commissioner to amend the petition after the close of the evidence and terminating Father's parental rights pursuant to ground (B)(ii). View "In re Gabriel S." on Justia Law

The Supreme Court affirmed the judgment of the appellate court affirming Defendant's conviction for the sale of a narcotic substance in violation of Conn. Gen. Stat. 21a-277(a), holding that Defendant was not entitled to relief on his allegations of error.On appeal to the appellate court, Defendant argued, as relevant to this appeal, that the trial court erred in imposing a discovery sanction precluding the admission of a written memorandum containing the inconsistent statement of a key state witness and in permitting the prosecutor to elicit expert opinion testimony on cross-examination of defense counsel's private investigator. The appellate court affirmed, holding (1) the discovery sanction was improper, but the error was harmless; and (2) even if the cross-examination at issue was improper, it was harmless. The Supreme Court affirmed, holding that the appellate court properly found that any error was harmless. View "State v. Massaro" on Justia Law

The Supreme Court affirmed the judgment of the appellate court affirming Defendant's conviction of burglary in the second degree, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Court held (1) Defendant's constitutional rights to confrontation, to present a defense, and to a fair trial under the Sixth and Fourteenth Amendments to the federal constitution were not violated during the underlying proceedings; and (2) assuming, without deciding, that the trial court abused its discretion when it limited defense counsel's cross-examination of the victim on the ground that the proffered line of questioning was speculative, Defendant failed to satisfy his burden of proving harm. View "State v. Lanier" on Justia Law

The Supreme Court affirmed the judgment of the appellate court reversing the trial court's judgment of strict foreclosure rendered against Defendant on the basis that Practice Book 23-18(a) did not apply as a matter of law in the instant case, holding that the appellate court did not err.In this action to foreclose a mortgage on some of Defendant's real property the trial court granted summary judgment for Plaintiff as to liability and entered a judgment of strict foreclosure, but the appellate court reversed. Plaintiff argued that the appellate court erroneously concluded that section 23-18(a) did not apply in this case because Defendant had objected to the mortgage debt amount. Plaintiff specifically argued that because Defendant failed to provide evidence supporting his claims that Plaintiff had miscalculated the amount of interest and municipal taxes he owed the trial court correctly allowed him to establish the amount of the debt by affidavit. The Supreme Court disagreed and affirmed, holding that the trial court erred allowing Plaintiff to establish the amount of the debt by affidavit. View "JPMorgan Chase Bank, National Ass'n v. Malick" on Justia Law

The Supreme Court affirmed the decision of the Public Utilities Regulatory Authority (PURA) establishing a regulatory framework for a certain renewable energy product, holding that the trial court correctly correctly determined that the reactions did not violate the dormant commerce clause.In 2020, PURA imposed a series of restrictions on retail electric suppliers offering Connecticut customers voluntary products, known as voluntary renewable offers (VROs), consisting of renewable energy credits (REC) bundled with electric supply. One of the restrictions at issue, the geographic restriction, prohibited VROs from containing RECs sourced outside of particular geographic regions. The other restriction, the marketing restriction, required suppliers to provide clear language informing consumers that a VRO backed by RECs is an energy product backed by RECs rather than a renewable energy itself. Plaintiffs argued that both restrictions violated the dormant commerce clause. The trial court rejected Plaintiffs' commerce clause arguments as to each restriction. The Supreme Court affirmed, holding that there was no error. View "Direct Energy Services, LLC v. Public Utilities Regulatory Authority" on Justia Law

The Supreme Court affirmed the judgment of the trial court dismissing the appeal brought by the Commission on Human Rights and Opportunities in this housing discrimination case, holding that this Court was compelled to affirm.For several years, Richard Cantillon harassed his neighbor, Kelly Howard, by making obscene gestures, calling her racial epithets, and physically menacing Howard. Howard eventually filed a neighbor versus neighbor claim with the Commission on Human Rights and Opportunities, alleging that Cantillon had violated her civil rights on account of her race. Cantillon defaulted, and the referee awarded Plaintiff $15,000 in damages. The Commission appealed the award as insufficient, but neither Howard nor Cantillon participated in the appeal. The trial court dismissed the appeal, concluding that there was no legal basis for it to second-guess the amount of the award. The court of appeals affirmed. The Supreme Court affirmed, holding that the appellate court appropriately resolved the Commission's claims under the circumstances of this case. View "Comm'n on Human Rights & Opportunities v. Cantillon" on Justia Law

The Supreme Court held that absolute immunity attaches to statements made in judicial or quasi-judicial proceedings and that while Jane Doe was not entitled to absolute immunity, a qualified privilege is appropriate for alleged victims of sexual assault presented in the context of this case.In disciplinary proceedings conducted at Yale University by the University-Wide Committee on Sexual Misconduct (UWC) Doe accused Plaintiff of sexual assault, resulting in Plaintiff's expulsion from Yale and criminal charges being brought against him. Plaintiff was acquitted. At issue in this appeal was whether Doe, who enjoyed absolute immunity in a subsequent civil action challenging her testimony given during Plaintiff's criminal proceeding, should likewise be afforded absolute immunity from suit for her statements made during the UWC proceeding. The Supreme Court held (1) absolute immunity attaches to statements in judicial or quasi-judicial proceedings; (2) the USC's proceeding did not meet the conditions necessary to be considered quasi-judicial, and therefore, Doe was not entitled to absolute immunity; but (3) due to the public interest in encouraging the proper reporting of sexual assaults a qualified privilege is appropriate for alleged victims of sexual assault at institutions of higher education. View "Khan v. Yale University" on Justia Law

The Supreme Court reversed the judgment of the appellate court affirming the decision of the Compensation Review Board upholding the finding and award of the Workers' Compensation Commissioner for the Second Districting ordering the town of Waterford to accept as compensable Plaintiff's claim for heart disease benefits pursuant to Conn. Gen. Stat. 7-433c, holding that the appellate court erred.In concluding that Plaintiff was entitled to benefits the Commissioner determined that section 7-433c does not define the phrase "uniformed member of a paid municipal fire department." The appellate court affirmed. On appeal, the town argued that the appellate court erred in determining that the definition of "member" in Conn. Gen. Stat. 7-425(5) does not govern whether the plaintiff was a uniformed member of a paid municipal fire department for purposes of section 7-433c. The appellate court affirmed. The Supreme Court reversed, holding that the definition of "member" in section 7-425(5) governs eligibility for benefits under section 7-433c. View "Clark v. Waterford, Cohanzie Fire Dep't" on Justia Law