Justia Connecticut Supreme Court Opinion Summaries

Two licensed wrecker services in Connecticut were summoned by state police to remove a severely damaged tractor trailer from a highway accident. The wrecker services used specialized equipment, including a costly rotator truck, to recover and tow the vehicle, then transported it to their storage facility. They sent an itemized invoice to the vehicle owner’s insurer, which included charges for the use of special equipment and supervisory personnel. The insurer paid the invoice under protest and subsequently filed a complaint with the Commissioner of Motor Vehicles, arguing that the charges were excessive and not permitted under state regulations.A Department of Motor Vehicles hearing officer determined that the wrecker services had overcharged for their nonconsensual towing services by using their own rate schedule based on equipment rather than the hourly labor rate set by the commissioner. Most equipment-based charges were disallowed, and the wrecker services were ordered to pay restitution and a civil penalty. The Superior Court dismissed the wrecker services’ administrative appeal, finding the hearing officer’s conclusions supported by substantial evidence. The Appellate Court affirmed, holding that the regulations required fees for exceptional services to be based solely on the hourly labor rate, excluding equipment costs.The Connecticut Supreme Court reviewed the case and concluded that the relevant regulation, § 14-63-36c (c), was ambiguous and could reasonably be interpreted to allow wrecker services to charge additional fees for exceptional services, including costs associated with special equipment, provided those fees are itemized and posted in accordance with regulatory requirements. The Court held that prohibiting such charges would prevent wrecker services from recouping necessary costs and could undermine the availability of exceptional towing services. The Supreme Court reversed the Appellate Court’s judgment in part and remanded the case for further proceedings consistent with its interpretation. View "Modzelewski's Towing & Storage, Inc. v. Commissioner of Motor Vehicles" on Justia Law

The defendant was convicted of murder and risk of injury to a child after fatally stabbing his long-term girlfriend in the presence of her twelve-year-old son. The relationship had deteriorated due to the defendant’s substance abuse and lack of financial contribution, leading the victim to attempt to end the relationship and remove the defendant from their shared home. On the morning of the incident, after a series of escalating arguments and failed attempts to have the defendant leave, the victim was attacked and killed. The defendant fled the scene, evaded police, and was eventually apprehended several days later.The case was tried before the Superior Court in the judicial district of New London. At trial, the defendant requested a jury instruction on the affirmative defense of extreme emotional disturbance, arguing that his mental state at the time of the killing warranted consideration of a lesser offense. The trial court denied this request, finding insufficient evidence that the defendant was under the influence of an extreme emotional disturbance, and the jury convicted him of both charges. The defendant appealed his conviction directly to the Connecticut Supreme Court, challenging the denial of the requested jury instruction.The Connecticut Supreme Court reviewed whether the trial court erred in refusing to instruct the jury on the affirmative defense of extreme emotional disturbance. The Court held that the trial court acted properly, concluding that no rational juror could find by a preponderance of the evidence that the defendant experienced an extreme emotional disturbance at the time of the murder. The Court emphasized the defendant’s actions before and after the crime, which demonstrated self-control and consciousness of guilt, and found that the evidence did not support the required loss of self-control. The judgment of conviction was affirmed. View "State v. Henderson" on Justia Law

The defendant was convicted of murder with special circumstances, home invasion, arson in the second degree, and robbery in the first degree, following a violent home invasion in Griswold, Connecticut. The crimes involved the planned theft of a gun safe and guns from the Lindquist family home, orchestrated with the help of the victims’ son, Matthew, who was later killed by the defendant and his sister, Ruth. After killing Matthew in a nearby wooded area, the defendant and Ruth entered the Lindquist home, killed Kenneth and Janet Lindquist, stole various items, and set the house on fire. The defendant’s cell phone was seized by police without a warrant after an interview, and a subsequent warrant authorized the search and seizure of “all data” from the phone, without any temporal limitations.In the Superior Court for the judicial district of New London, the defendant moved to suppress evidence obtained from his cell phone, arguing the seizure was illegal and the warrant was unconstitutional due to its broad scope. The trial court found the seizure proper and, applying the severance doctrine, limited admissible evidence to data created or received within a two-week period surrounding the crimes, suppressing data outside that window. The jury convicted the defendant on most counts, and the court vacated certain convictions before sentencing him to life imprisonment without parole.On appeal to the Connecticut Supreme Court, the defendant challenged the constitutionality of the cell phone search warrant. The Supreme Court assumed, without deciding, that the warrantless seizure was constitutional, but held that the warrant violated the Fourth Amendment’s particularity requirement because it authorized a search of all data without content or time limits. The Court further found the trial court erred in applying the severance doctrine to cure the warrant’s deficiencies. Nevertheless, the Supreme Court concluded that the error was harmless beyond a reasonable doubt, as the cell phone evidence was cumulative and the state’s case was strong without it. The judgment of conviction was affirmed. View "State v. Correa" on Justia Law

A woman was injured when a heat lamp manufactured by a company made contact with her foot during an acupuncture session performed by a physician. She initially sued the physician and his employer for medical malpractice. The physician then filed a third-party complaint against the manufacturer, alleging product liability. The injured woman subsequently filed a direct product liability claim against the manufacturer. The manufacturer raised special defenses, asserting that both the woman and the physician bore comparative responsibility for her injuries and that, if found liable, it would be entitled to contribution from the physician. Before trial concluded, the physician withdrew his third-party complaint. The jury found the manufacturer 80 percent responsible and the physician 20 percent responsible for the woman’s damages.After judgment was rendered, the Connecticut Appellate Court reversed the judgment as to the medical malpractice claim against the physician for lack of personal jurisdiction but affirmed the product liability judgment, including the jury’s allocation of comparative responsibility. The Connecticut Supreme Court denied the manufacturer’s petition for certification to appeal, and the woman withdrew her appeals after receiving payment in satisfaction of the judgment.The manufacturer and its insurer then filed a contribution action against the physician, seeking to recover 20 percent of the amount paid to the injured woman. The Superior Court granted summary judgment in favor of the manufacturer and its insurer. On appeal, the physician argued that he was not a party subject to the comparative responsibility provisions of the Connecticut Product Liability Act and that the contribution action was untimely.The Connecticut Supreme Court held that all defendants in an action involving a product liability claim, regardless of whether they are product sellers, are subject to comparative responsibility under the statute. The Court also held that a contribution action is timely if brought within one year after all appellate proceedings in the underlying action are final. The judgment in favor of the manufacturer and its insurer was affirmed. View "Health Body World Supply, Inc. v. Wang" on Justia Law

The plaintiffs purchased a one-year homeowners insurance policy through an insurance broker, after previously having a long-term relationship with that broker, which had been interrupted for two years when the plaintiffs used a different broker. After the policy was issued, the insurer inspected the plaintiffs’ home and found a defect in the siding, requiring repairs as a condition for continued coverage. The insurer communicated this requirement and the risk of nonrenewal to the broker, but the parties disputed whether the broker relayed this information to the plaintiffs. The insurer did not receive proof of repair and sent a nonrenewal notice to the plaintiffs by certified mail, which the plaintiffs claimed they never received. The policy expired without renewal, and shortly thereafter, the plaintiffs’ home was destroyed by fire. The insurer denied coverage because the policy had lapsed.The plaintiffs sued the broker and the brokerage firm in the Superior Court, alleging, among other claims, that the broker negligently failed to notify them of the insurer’s communications and the impending nonrenewal. The trial court granted summary judgment in favor of the broker, finding no legal duty to notify the plaintiffs of nonrenewal after procuring the policy. The Appellate Court affirmed, holding that the broker’s duty ended once the policy was procured, absent evidence of an agreement to assist with renewal or maintain coverage, and that the plaintiffs’ long-standing relationship with the broker was insufficient to create such a duty.The Supreme Court of Connecticut affirmed the Appellate Court’s judgment. It held that, under Connecticut law, an insurance broker generally owes no duty to notify clients of an insurer’s intent not to renew a policy after the broker has procured the requested coverage, unless the broker has expressly or impliedly agreed to assist with renewal. The Court found no evidence of such an agreement or ongoing duty in this case. View "Deer v. National General Ins. Co." on Justia Law

A woman was found dead in her apartment after her boyfriend, who had spent the night elsewhere, returned and discovered her body hidden in a closet. The apartment was in disarray, and drugs and a cell phone were missing. The defendant, who knew the victim and her boyfriend through drug transactions, was identified as having been at the apartment the night of the murder. Forensic evidence linked the defendant to the crime scene, including blood matching the victim on his clothing and blood matching the defendant at the scene. The defendant was arrested shortly after the murder, and additional evidence was gathered, including statements from jailhouse informants.The defendant was first convicted of murder in the Superior Court for the judicial district of New London, but the Connecticut Supreme Court reversed that conviction and ordered a new trial due to the improper admission of evidence obtained in a warrantless search. Before the second trial, the defendant requested a new probable cause hearing, which the trial court denied, reasoning that the reversal did not invalidate the original probable cause finding. The trial court also denied motions to exclude testimony from two jailhouse informants: one, who had suffered a stroke and claimed memory loss, and another whose reliability was challenged.On appeal, the Connecticut Supreme Court held that the defendant was not entitled to a second probable cause hearing after reversal and remand for a new trial, as neither the state constitution nor the relevant statute required it absent a jurisdictional defect. The court also held that admitting the prior written statement of the former cellmate did not violate the defendant’s confrontation rights, as the witness was present, took an oath, and answered questions, even if he claimed memory loss. The court further found no abuse of discretion in admitting the statement as a prior inconsistent statement or in finding the jailhouse informant’s testimony reliable. The judgment of conviction was affirmed. View "State v. Jacques" on Justia Law

The petitioner, who had previously been convicted of robbery in the first degree following a guilty plea, filed a habeas petition in 2018 challenging that conviction on the grounds of ineffective assistance of trial counsel. In 2020, the petitioner was deported to Jamaica. After deportation, his habeas counsel was unable to contact him or his family members. In early 2021, the habeas court scheduled a hearing to consider dismissing the petition due to the petitioner’s failure to appear and prosecute the case with due diligence. Following the hearing, the court dismissed the habeas petition for lack of prosecution.Approximately fifteen months after the dismissal, the petitioner filed a motion to open the judgment, arguing that he had not received notice of the hearing and that his counsel had failed to make reasonable efforts to notify him or communicate effectively. The Superior Court denied the motion, finding that the petitioner had not established a recognized basis for opening the judgment beyond the four-month period prescribed by Connecticut General Statutes § 52-212a. The petitioner appealed, and the Connecticut Appellate Court reversed, holding that a claim of ineffective assistance of habeas counsel was sufficient to invoke the habeas court’s common-law authority to grant a late motion to open a judgment.On further appeal, the Supreme Court of Connecticut reviewed whether ineffective assistance of habeas counsel could serve as a common-law exception to the four-month deadline in § 52-212a. The Supreme Court held that the phrase “unless otherwise provided by law” in § 52-212a does not include a new judicially created common-law exception for ineffective assistance of habeas counsel. The Court reasoned that such an exception would conflict with the statutory scheme governing habeas corpus, including requirements for expedient resolution and custody status. The Supreme Court reversed the Appellate Court’s judgment and directed affirmation of the habeas court’s denial of the motion to open. View "Clue v. Commissioner of Correction" on Justia Law

In 1997, an individual diagnosed with schizophrenia and alcohol use disorder attacked his father, resulting in serious injuries. He was charged with several offenses, including attempted murder and first-degree assault. At trial, he was found not guilty by reason of mental disease or defect and was committed to the custody of the Psychiatric Security Review Board for up to twenty years. Over the years, his commitment was extended multiple times, sometimes by agreement and sometimes after evidentiary hearings, based on findings that he remained a danger to himself or others. His condition improved over time, leading to less restrictive placements and eventual conditional release into the community, though he experienced a setback in 2020 that led to brief rehospitalization.After the expiration of his initial commitment, the state repeatedly sought and obtained extensions of his commitment. In 2022, the state filed another petition to extend his commitment. The acquittee moved to dismiss, arguing that the statutory commitment procedure violated his constitutional right to equal protection. The Superior Court, Judicial District of Middlesex, denied the motion and, after a hearing, found clear and convincing evidence that he remained dangerous, extending his commitment for two more years, until March 2025. The acquittee appealed, and the Connecticut Supreme Court granted transfer of the appeal.While the appeal was pending, the state filed a new petition to extend the commitment beyond 2025. The Board, however, found the acquittee was no longer dangerous and recommended denial of the petition. The state withdrew its petition, resulting in the acquittee’s discharge in March 2025. The Connecticut Supreme Court held that the appeal was moot because the acquittee had been released and no practical relief could be granted. The Court found neither the collateral consequences doctrine nor the “capable of repetition, yet evading review” exception applied. However, to avoid any lingering effects, the Court vacated the 2023 commitment order. View "State v. Guild" on Justia Law

A man was found not guilty by reason of mental disease or defect for several violent offenses, including first-degree burglary, risk of injury to a child, third-degree assault, and possession of a weapon on school grounds. He was committed to the jurisdiction of the Psychiatric Security Review Board in 2003 for up to ten years. His commitment was extended several times by agreement, but in 2018, he was granted conditional release and began living in the community under strict conditions related to his mental health treatment. In 2019, the state petitioned to extend his commitment, arguing that his discharge would pose a danger to himself or others.The Superior Court, judicial district of Stamford-Norwalk, denied the acquittee’s motion to dismiss the petition, which had argued that the recommitment procedure violated his federal equal protection rights. The court found, by clear and convincing evidence, that he continued to suffer from a psychiatric illness and posed a danger if released without supervision, and extended his commitment. The Appellate Court affirmed, holding that the recommitment scheme did not violate equal protection and that the trial court’s finding of dangerousness was not clearly erroneous.The Connecticut Supreme Court reviewed the case. It held that individuals found not guilty by reason of insanity and subject to recommitment are not similarly situated to civilly committed inmates for equal protection purposes, because the former’s commitment is based on a judicial finding that their criminal acts were caused by mental illness, while civilly committed inmates may develop mental illness unrelated to their criminal conduct. The Court also held that the trial court’s finding that the acquittee’s discharge would be dangerous was supported by clear and convincing evidence, given his history, the violent nature of his offenses, and the short duration of his stable conditional release. The judgment of the Appellate Court was affirmed. View "State v. Foster" on Justia Law

The case involved a defendant who owned a moving business in Connecticut and was accused of murdering a former employee, Reginald, following a dispute during a moving job in Virginia. After a physical altercation between the defendant and Reginald, Reginald returned to Connecticut. Days later, Reginald was shot outside his apartment in Bridgeport. Surveillance footage captured a dark SUV, similar to the defendant’s vehicle, near the scene, and a man exiting the vehicle. A lay witness, May, who had met the defendant only once during the Virginia altercation, later identified the defendant from a still photograph taken from the surveillance footage. Police also recovered a firearm linked to the crime and obtained cell site location information (CSLI) for the defendant’s phone, which placed him near the crime scene and later near the location where the firearm was found.The Superior Court in the judicial district of Fairfield denied in part the defendant’s motion to suppress the CSLI and allowed May’s identification testimony. The jury convicted the defendant of murder and carrying a pistol without a permit. The defendant appealed directly to the Connecticut Supreme Court, arguing that the trial court erred in admitting May’s identification and in denying the motion to suppress the CSLI.The Connecticut Supreme Court affirmed the conviction. It held that the trial court did not abuse its discretion in admitting May’s identification testimony, finding that May’s single but focused encounter with the defendant provided more than minimal familiarity, and that the totality of circumstances—including the quality of the photograph and changes in the defendant’s appearance—supported admissibility. The Court also held that the search warrant affidavit established probable cause for obtaining CSLI for the period immediately surrounding the crime, and any error in the warrant’s broader scope was harmless since only relevant CSLI was introduced at trial. View "State v. Evans" on Justia Law