Justia Connecticut Supreme Court Opinion Summaries

Three registered electors from Bridgeport filed a writ of error challenging a trial judge's decision to deny their applications for arrest warrants for two individuals who allegedly violated election laws during the 2023 Democratic primary for the mayoral office. The plaintiffs claimed that the trial judge misinterpreted the relevant statute, General Statutes § 9-368, which they argued mandated the issuance of arrest warrants upon their complaint. The state of Connecticut, the defendant in error, argued that the writ should be dismissed because the plaintiffs were neither statutorily nor classically aggrieved by the denial of their applications.The Superior Court for the judicial district of Fairfield, with Judge Thomas J. Welch presiding, denied the applications for arrest warrants. The judge concluded that § 9-368 was inconsistent with the federal and state constitutions and the rules of practice, as it allowed for the issuance of arrest warrants based on a standard less than probable cause and without coordination with the Division of Criminal Justice. The judge did not reach the substantive merits of the applications and suggested that the matter could be referred to a prosecuting authority.The Supreme Court of Connecticut reviewed the case. The court held that the plaintiffs in error were not required to establish statutory aggrievement to bring a writ of error. However, the court dismissed the writ on the grounds that the plaintiffs were not classically aggrieved. The court determined that the plaintiffs lacked a specific, personal, and legal interest in the arrest and prosecution of those who allegedly violated election laws, as they were private citizens without a judicially cognizable interest in the prosecution or nonprosecution of another. Consequently, the plaintiffs did not have standing to challenge the trial judge's denial of their arrest warrant applications. View "In re Criminal Complaint & Application for Arrest Warrant" on Justia Law

The plaintiff, a self-represented pediatric dentist, sued the defendant newspaper for defamation, alleging that two articles published by the defendant exaggerated the scope and seriousness of disciplinary proceedings against him. The articles reported on disciplinary actions taken by the Department of Public Health and the Connecticut State Dental Commission, which resulted in a reprimand, fines, and probation of the plaintiff’s dental license. The plaintiff claimed that five statements in the articles were defamatory and that a stock photograph accompanying the articles was independently defamatory.The trial court granted summary judgment in favor of the defendant, concluding that the five statements were either substantially true or protected by the fair report privilege under the First Amendment. The court did not address the photograph as an independent defamation claim, as the plaintiff had not distinctly raised it as such in his pleadings. The plaintiff appealed, and the Appellate Court affirmed the trial court’s judgment, declining to consider the photograph claim because it was not distinctly raised before the trial court.The Connecticut Supreme Court reviewed the case and affirmed the Appellate Court’s decision. The court held that the trial court did not err in granting summary judgment without treating the plaintiff’s references to the photograph as an independent defamation claim. The court emphasized that the plaintiff’s self-represented status did not relieve him of the obligation to sufficiently articulate his claims. The court also clarified that the fair report privilege is not defeated by demonstrating malice in fact, and that the privilege applies as long as the report is a fair and substantially accurate account of the proceedings. View "Idlibi v. Hartford Courant Co." on Justia Law

The case involves a billing dispute between a group of emergency room physicians (plaintiff) and an insurance company (defendant). The dispute centers on the interpretation of Connecticut’s surprise billing law, which aims to protect insured individuals from high medical bills when they receive emergency care from out-of-network providers. The plaintiff contends that the law requires the defendant to fully reimburse them for emergency services and then collect any applicable cost-sharing amounts (deductibles, copayments) from the insured. The defendant argues that it can deduct the insured’s cost-sharing amounts from the reimbursement it pays to the plaintiff.The United States District Court for the District of Connecticut dismissed the plaintiff’s stand-alone claims under the surprise billing law, concluding that the law does not create a private right of action. The court then certified three questions to the Connecticut Supreme Court: (1) whether a CUTPA claim can be maintained for conduct that violates the surprise billing law but not CUIPA, (2) whether the surprise billing law requires insurers to fully reimburse providers and then collect cost-sharing amounts from insureds, and (3) whether the defendant’s practice of deducting cost-sharing amounts from reimbursements violates the surprise billing law.The Connecticut Supreme Court held that Connecticut law does not recognize a cause of action under CUTPA for conduct that violates the surprise billing law but is not identified as an unfair insurance practice under CUIPA. The court also held that the surprise billing law does not require insurers to fully reimburse providers and then collect cost-sharing amounts from insureds. Instead, insurers can deduct the insured’s cost-sharing amounts from the reimbursement paid to the provider. Finally, the court concluded that the defendant’s practice of deducting cost-sharing amounts from reimbursements does not violate the surprise billing law. View "NEMS, PLLC v. Harvard Pilgrim Health Care of Connecticut, Inc." on Justia Law

The defendant was convicted of murder, criminal possession of a pistol or revolver, and carrying a pistol or revolver without a permit. The case involved the shooting death of the victim, Eric Diaz, who was selling drugs when he was approached by a man, later identified as the defendant, and a fight ensued in a black car, resulting in the victim being shot in the abdomen. The victim died from the gunshot wound. The police identified the car as a Nissan Maxima with a broken rear vent window, registered to Frank Bridgeforth but driven by the defendant. Forensic evidence and eyewitness testimonies linked the defendant to the crime.The trial court asked questions to three witnesses, including a police officer and two defense experts, which the defendant claimed were biased and prejudicial. The trial court’s questions aimed to clarify the preparation of a photographic array and the presence of gunshot residue in the car. The defendant did not object to these questions during the trial. The jury was instructed that the court’s questions should not influence their judgment.The Connecticut Supreme Court reviewed the case and found that the trial court’s questioning did not violate the defendant’s due process rights. The court held that the questions were not extensive or adverse enough to impair the jury’s function or the judge’s impartiality. The court also found sufficient evidence to support the defendant’s intent to kill, given the close-range shooting in a vital area and the defendant’s flight from the scene.The defendant’s claims of improper jury instructions were deemed waived because defense counsel had a meaningful opportunity to review and did not object to the instructions. The court concluded that the instructions, when viewed as a whole, were not clearly erroneous and did not constitute plain error. The judgment was affirmed. View "State v. Mebane" on Justia Law

The plaintiff sought damages from the defendant for negligence related to a motor vehicle accident. The original action was dismissed due to insufficient service of process, as the defendant had moved from the address where service was attempted. The plaintiff then filed a new action under the accidental failure of suit statute, § 52-592.The trial court granted the defendant's motion for summary judgment, concluding that the original action was not commenced within the time limited by law because the defendant did not receive the summons and complaint within the statutory period. The Appellate Court affirmed, agreeing that the defendant did not have actual or effective notice of the original action within the required time frame.The Supreme Court of Connecticut reviewed the case and affirmed the Appellate Court's decision. The court held that for an action to be "commenced" under § 52-592, the defendant must receive the summons and complaint within the time permitted by law, even if the service was improper. The court found that the plaintiff failed to establish that the defendant or her agent received the summons and complaint within the statutory period. Therefore, the original action was not commenced within the meaning of § 52-592, and the plaintiff could not rely on the savings statute to file a new action. View "Laiuppa v. Moritz" on Justia Law

The case involves a dispute between divorced parents over the custody and visitation rights of their minor children. The plaintiff father was granted sole legal custody of the children, while the defendant mother was given limited visitation rights. The trial court's order allowed the plaintiff to unilaterally suspend the defendant's visitation with their son, R, if he reasonably determined, after consulting with R's therapist, that the visits were causing negative behavioral or emotional consequences for R.The trial court initially granted the plaintiff's motion to modify custody, awarding him sole legal custody and primary physical custody of the children. The court found that the defendant's behavior, including her mistrust and denigration of the plaintiff, negatively impacted the children. The court's order allowed the defendant to have supervised visits with R, which could become unsupervised if the plaintiff approved. However, the plaintiff was also given the authority to suspend the defendant's visitation if he believed it was harming R.The Connecticut Supreme Court reviewed the case and concluded that the trial court's order improperly delegated judicial authority to the plaintiff. The court held that a trial court cannot delegate its statutory duty to decide custody and visitation matters to a nonjudicial entity, including a parent. The court emphasized that only the trial court has the authority to modify visitation orders and that delegating this authority to a parent creates a situation ripe for abuse and misjudgment. The court reversed the trial court's order to the extent that it allowed the plaintiff to unilaterally suspend the defendant's visitation rights and remanded the case for further proceedings on this issue. View "R. H. v. M. H." on Justia Law

The defendant was convicted of multiple counts of sexual assault and risk of injury to a child based on allegations of sexual abuse involving his children, B, J, and D. The charges included sexual assault in the first degree, sexual assault in the fourth degree, and risk of injury to a child. The defendant appealed, arguing insufficient evidence, statute of limitations issues, improper admission of sexual misconduct evidence, and violations of his confrontation rights.The trial court joined the cases for trial, and the jury found the defendant guilty on all counts. The trial court vacated some convictions as lesser included offenses and sentenced the defendant to a total effective term of twenty-five years, suspended after fifteen years, followed by twenty years of probation.On appeal, the Connecticut Supreme Court found insufficient evidence to support the defendant’s conviction of sexual assault in the first degree and the vacated conviction of sexual assault in the fourth degree involving J. The court noted that the state failed to prove that the defendant touched J’s genitals with his mouth, lips, or tongue, a necessary element for these charges.The court also agreed with the defendant that his convictions of sexual assault in the first degree and risk of injury to a child involving B should be reversed under the plain error doctrine. The trial court failed to obtain the defendant’s knowing and voluntary waiver of the statute of limitations, which had expired before the charges were filed.The court rejected the defendant’s claims regarding the improper admission of sexual misconduct evidence and found that the trial court did not abuse its discretion in admitting this evidence. The court also found no error in the trial court’s decision not to conduct an in camera review of J’s and B’s psychiatric records and in declining to release D’s psychiatric records.The Connecticut Supreme Court reversed the convictions related to B and the conviction of sexual assault in the first degree related to J, remanding the case for resentencing on the remaining convictions. The judgments were affirmed in all other respects. View "State v. Daren Y." on Justia Law

The defendant was convicted of murder and criminal possession of a firearm. The case involved the shooting of the victim, Derrick Nichols, who was found dead near the defendant's vehicle. An eyewitness, Sheleese Lockhart, testified that she saw the victim being shot from inside the defendant's car. The police recovered several items belonging to the victim and shell casings from the crime scene. Gunshot residue tests on the defendant's hands, clothing, and car revealed particles consistent with gunshot residue.The trial court admitted the gunshot residue evidence and allowed expert testimony on the matter. However, it precluded the defendant's expert from testifying about surveillance footage that the defense argued showed the victim walking outside the car before being shot, contradicting the eyewitness testimony. The trial court applied the standard for nonpercipient witness identification rather than the standard for expert testimony.The Connecticut Supreme Court reviewed the case. It held that the evidence was sufficient to support the jury's verdict, as the physical evidence did not render the state's theory of the case a physical impossibility. The court found that the trial court improperly applied the wrong standard in precluding the defendant's expert testimony about the surveillance footage. This error was not harmless because the expert's testimony could have challenged the credibility of the state's key eyewitness. Therefore, the court reversed the judgment of conviction and remanded the case for a new trial.The court also addressed the admissibility of the gunshot residue evidence, concluding that the trial court did not abuse its discretion in admitting expert testimony that one and two element particles consistent with gunshot residue were found on the defendant and in his vehicle. The probative value of this evidence was not outweighed by the danger of unfair prejudice. View "State v. Williams" on Justia Law

The case involves a dispute between a property owner and a city regarding the validity of a lien placed on the property. The property, an apartment building, was destroyed by arson, leading to the displacement of its tenants. The city incurred costs relocating the tenants and placed a lien on the property to recover these expenses under the Uniform Relocation Assistance Act (URAA).The trial court ruled in favor of the property owner, determining that the lien was invalid because the displacement was caused by a third party's arson, not by the city's enforcement of its building code. The court allowed the property owner to challenge the lien using an affirmative defense provided by the URAA, which is typically available only in civil actions brought by a municipality to recover relocation expenses.The Supreme Court of Connecticut reviewed the case and reversed the trial court's decision. The Supreme Court held that the tenants were "displaced persons" under the URAA because their displacement was a direct result of the city's enforcement of its building code, regardless of the arson being the initial cause. The court further held that the affirmative defense provided by the URAA, which allows a landlord to argue that the displacement was not due to their violation of housing codes, is only available in civil actions brought by the municipality and cannot be used to challenge a lien in an application to discharge it.The Supreme Court directed the trial court to deny the property owner's application to discharge the city's lien, thereby upholding the city's right to recover its relocation expenses through the lien. View "PPC Realty, LLC v. Hartford" on Justia Law

The defendant was convicted of murder as an accessory and conspiracy to commit murder. She waived her right to a jury trial and opted for a trial by a three-judge panel. The defendant argued that the evidence was insufficient to support her conviction and that her waiver of a jury trial was not made knowingly, intelligently, and voluntarily because the canvassing court failed to explain that the three-judge panel did not need to be unanimous to convict. Additionally, she claimed that the panel improperly began deliberations before the close of evidence.The trial court found the defendant guilty based on evidence including her tumultuous relationship with the victim, her presence near the crime scene, and her inconsistent statements to the police. The defendant had initially claimed she was at home during the shooting but later admitted to being picked up by her cousin near the scene. Phone records also showed she contacted her cousin multiple times shortly before the murder.The Connecticut Supreme Court held that the evidence was sufficient to support the defendant’s conviction. The court noted that the defendant’s presence at the scene, her actions during the crime, and her inconsistent statements provided a reasonable basis for the panel’s verdict.However, the court invoked its supervisory authority to require that trial courts must specifically advise defendants who waive their right to a jury trial in favor of a three-judge panel that only two of the three judges need to agree to convict, unlike a jury which must be unanimous. The court concluded that this new rule should apply to the defendant’s case, reversed her conviction, and ordered a new trial.The court also addressed the defendant’s claim regarding premature deliberations by the panel, concluding that unlike juries, three-judge panels are not constitutionally prohibited from discussing the case before the close of evidence. View "State v. King" on Justia Law