Justia Connecticut Supreme Court Opinion Summaries

A business in Connecticut was assessed personal property taxes from 2008 to 2016. The defendant, who had moved to California years earlier and claimed to have left the business by 2007, was never notified of these tax assessments at her California address, despite having provided it to the tax collector in 2011 and 2016. Over the years, the city’s tax collector took funds from the defendant’s bank accounts multiple times via bank executions to satisfy the tax debt, without ever sending her a tax bill or notice at her actual residence.In 2021, the tax collector initiated another bank execution against the defendant. The defendant challenged this action, arguing she had not received due process or required statutory notice. The Superior Court for the judicial district of Litchfield held an evidentiary hearing and agreed with the defendant, finding the tax collector failed to provide required notice under General Statutes § 12-155 (a) and that the lack of notice deprived her of the opportunity to challenge the tax assessment. The court granted the defendant’s exemption motion, rendering the execution “of no effect.” The tax collector initially appealed but then withdrew the appeal. After sending a written demand to the defendant’s California address, the tax collector initiated a new bank execution, again without providing a new tax bill or an opportunity to challenge it.The trial court found the new action was a collateral attack on the earlier judgment and barred by collateral estoppel. The Appellate Court affirmed, concluding the issue of notice and opportunity to challenge had been actually litigated and necessarily determined in the 2021 action.The Connecticut Supreme Court affirmed the Appellate Court’s judgment. It held that, under Connecticut law, collateral estoppel applies to all independent, alternative grounds actually litigated and determined in a prior judgment, making them preclusive in subsequent actions. Thus, the tax collector was barred from relitigating the notice and due process issues already decided. The Court declined to recognize a public policy exception for municipal tax collection cases. View "Torrington Tax Collector, LLC v. Riley" on Justia Law

Several individuals who worked as warehouse associates at fulfillment centers operated by the defendants brought a class action, claiming that they and similarly situated employees were not paid for time spent undergoing mandatory security screenings before being allowed to leave the premises at the end of their shifts. The screenings, required by the employer, varied in duration depending on the items employees carried, and could range from a few seconds to up to twenty minutes. The plaintiffs alleged that this uncompensated time violated Connecticut wage laws, specifically the statutory definition of “hours worked,” and sought damages and related relief.The case was filed in Connecticut Superior Court, but was removed to the United States District Court for the District of Connecticut. The defendants moved for summary judgment, arguing that Connecticut’s wage laws were intended to mirror the federal Fair Labor Standards Act (FLSA), as amended by the Portal-to-Portal Act, and cited Integrity Staffing Solutions, Inc. v. Busk, in which the United States Supreme Court determined that such security screening time was not compensable under federal law. The District Court agreed, finding that the time was not compensable under Connecticut law and entered summary judgment for the defendants. The plaintiffs appealed to the United States Court of Appeals for the Second Circuit, which certified questions to the Supreme Court of Connecticut regarding whether Connecticut law requires compensation for such time and whether a de minimis exception applies.The Supreme Court of Connecticut held that, under Connecticut law, employees must be compensated for all time during which they are required by the employer to remain on the employer’s premises, including time spent undergoing mandatory security screenings, as this constitutes “hours worked” under the relevant statute. The court also clarified that Connecticut law does not recognize a de minimis exception to compensability, distinguishing its law from federal standards and regulations. View "Del Rio v. Amazon.com Services, Inc." on Justia Law

A man was convicted for the shooting death of another individual following an altercation that began after the victim drove past a group of people, including the defendant, with a loud noise from his truck. The defendant followed the victim, confronted him, and after a struggle over a BB gun, fired several shots, killing the victim. At trial, the defendant asserted that he acted in self-defense, claiming he believed the victim was about to shoot him with the BB gun.The case was tried in the Superior Court in the judicial district of New Haven. The jury acquitted the defendant of murder but found him guilty of the lesser included offense of intentional manslaughter in the first degree with a firearm, as well as carrying a pistol or revolver without a permit, and criminal possession of a firearm. The defendant was sentenced to a total effective sentence of thirty-three years imprisonment. He appealed his conviction, raising claims regarding jury instructions and sufficiency of the evidence.The Supreme Court of Connecticut reviewed the defendant’s claims. The court held that the federal constitution does not require jury unanimity as to which specific statutory disqualification to self-defense the state has proven, so long as the jurors unanimously agree that the state has disproved the defense of self-defense beyond a reasonable doubt. The court further found that the trial court’s jury instructions were not misleading regarding the initial aggressor doctrine, the “words alone” principle, or the state of mind required for lesser included offenses. Finally, the Supreme Court concluded that there was sufficient evidence for the jury to find that the defendant did not justifiably act in self-defense and that he acted with specific intent to cause serious physical injury. Accordingly, the judgment of conviction was affirmed. View "State v. Matheney" on Justia Law

The case concerns a petitioner who was convicted of felony murder, robbery in the first degree, and conspiracy to commit robbery in the first degree, stemming from the fatal shooting of a man who had arranged to sell electronic tablets via Craigslist. The victim was lured to a location in Hartford, where he was shot and killed during an attempted robbery. Evidence at trial included statements and admissions by the petitioner, testimony linking him to the scene, and communications involving his alleged coconspirator, Mathis. After the petitioner’s conviction, Mathis was tried separately and found not guilty by reason of mental disease or defect, under a Connecticut statute that excuses criminal liability if a defendant, due to mental impairment, cannot appreciate the wrongfulness of his actions or conform his conduct to the law.After his conviction was affirmed on direct appeal, the petitioner sought habeas corpus relief in the Superior Court for the judicial district of Tolland, arguing that Mathis’s subsequent acquittal and the evidence from Mathis’s trial constituted newly discovered evidence proving the petitioner’s actual innocence, as a valid conspiracy under Connecticut law requires both parties to possess criminal intent. The habeas court denied relief, concluding that Mathis’s acquittal was legally irrelevant based on precedent allowing inconsistent verdicts for separately tried coconspirators. The Appellate Court disagreed with the habeas court’s reasoning, holding that evidence from Mathis’s trial should be considered in the actual innocence analysis. However, it affirmed the denial of habeas relief on the alternative ground that there was sufficient evidence of a conspiracy between the petitioner and a third party.The Connecticut Supreme Court reviewed the case. It held that, while the Appellate Court correctly required consideration of all aggregate evidence, Mathis’s acquittal did not clearly and convincingly demonstrate Mathis’s incapacity to form criminal intent, as the acquittal was based on a lower standard of proof and did not necessarily negate specific intent. Therefore, the petitioner failed to meet the high burden of proving actual innocence, and the judgment was affirmed. View "Moon v. Commissioner of Correction" on Justia Law

A candidate for the South Windsor town council in the November 2025 municipal election challenged the town clerk’s decision regarding the application of revisions to the town charter. During the same election in which council members were chosen, voters also approved, by referendum, changes to the charter that altered the party composition rules for the council, reducing the maximum number of members who could be from the same political party from six to five. The town clerk determined that these new limits applied immediately to the 2025 election, even though meeting minutes from the Charter Revision Commission indicated the changes would not take effect until 2027. As a result, the clerk declared a Republican candidate, rather than the plaintiff (a Democrat who otherwise would have won under the prior rules), as the winner of the final council seat.A lawsuit was filed in the Superior Court for the judicial district of Hartford under statutes providing expedited review for those aggrieved by rulings of election officials in municipal elections. The plaintiff argued that the clerk’s decision to apply the new charter revisions to the 2025 election was erroneous. The trial court dismissed the action, concluding it lacked subject matter jurisdiction because the clerk’s decision was not a “ruling of an election official” within the meaning of the relevant statutes.On appeal, the Connecticut Supreme Court addressed whether the clerk’s determination constituted a “ruling of an election official” for the purposes of the statutes governing election disputes. The court held that the town clerk’s decision to apply the newly adopted charter provisions to the current election was indeed a ruling of an election official. The Supreme Court reversed the trial court’s dismissal and remanded the case for further proceedings. The decision clarified that applying or interpreting laws affecting the determination of election outcomes falls within the statutory jurisdiction for expedited election challenges. View "Amadasun v. Armstrong" on Justia Law

The case involves a defendant who was convicted by a jury of manslaughter in the first degree with a firearm after shooting his girlfriend in the head with a revolver while she was sitting in a small bathroom of their shared residence. The prosecution presented forensic evidence suggesting the defendant pressed the loaded, fully-cocked revolver against the victim’s head before firing. The defense argued the shooting was accidental, claiming the gun—known to have a very light “hair trigger”—discharged when the defendant tripped on the bathroom doorframe while holding it.The Superior Court for the judicial district of New Haven conducted the trial, and the jury found the defendant guilty. The trial court did not provide an express jury instruction on general intent, and neither party requested one. The defendant appealed to the Connecticut Appellate Court, arguing under the plain error doctrine that the absence of a general intent instruction required reversal. The Appellate Court agreed, finding that the jury could have convicted the defendant without determining whether his actions were volitional, and reversed the conviction, ordering a new trial.The Supreme Court of Connecticut reviewed the case upon the state’s appeal. The Supreme Court held that the trial court’s failure to provide a stand-alone general intent instruction did not constitute plain error. The Court reasoned that the element of general intent was necessarily included in the instruction on recklessness, which required the jury to find that the defendant acted with awareness and conscious disregard of a substantial risk. The Supreme Court concluded that the omission did not result in a manifest injustice and reversed the Appellate Court’s judgment, directing it to affirm the conviction. View "State v. Anthony V." on Justia Law

After a motor vehicle accident in Norfolk, Connecticut, downed electrical wires from a utility pole owned by an electric supplier trapped the vehicle’s occupants. First responders waited about an hour before the utility’s specialist confirmed the wires were de-energized, delaying rescue. The Public Utilities Regulatory Authority (PURA) investigated the supplier’s response, conducted a hearing in which the supplier participated, and ultimately found the response imprudent. PURA ordered the supplier to adopt a thirty-minute target response time for certain life-threatening situations, among other directives.The electric supplier appealed PURA’s decision to the Superior Court, arguing that the investigation and hearing constituted a “contested case” under Connecticut’s Uniform Administrative Procedure Act, which would entitle it to judicial review. The Superior Court rejected this argument, finding that the statutes and regulations cited by the supplier did not require PURA to hold a hearing in these circumstances, and therefore the proceeding did not qualify as a contested case. The court dismissed the supplier’s administrative appeal for lack of subject matter jurisdiction.On further appeal, the Connecticut Supreme Court affirmed the Superior Court’s dismissal. The Supreme Court held that the proceeding was not a contested case because no state statute or regulation required PURA to determine the supplier’s legal rights, duties, or privileges after an opportunity for a hearing in this context. The Court explained that references to statutes requiring hearings in other circumstances did not convert the proceeding into a contested case when the relevant factual predicates were absent. The holding also clarified that PURA’s decision to hold a hearing voluntarily, or to follow contested case procedures, did not create contested case status where no such hearing was legally mandated. Thus, PURA’s determinations and orders in this investigation were not subject to judicial review under the contested case provisions. View "Connecticut Light & Power Co. v. Public Utilities Regulatory Authority" on Justia Law

The case involves a defendant who, in 2020, confronted individuals renting his neighbor’s house through Airbnb by approaching them with a shotgun, using racial slurs, and threatening them. He also left threatening voicemails for the property owner, making explicit references to race. The defendant was charged in two separate cases: one involving the renters (with charges including reckless endangerment and threatening) and another involving the neighbor (with charges including intimidation based on bigotry or bias and harassment). Ultimately, under a plea agreement, the defendant pleaded guilty to reckless endangerment in the second degree, threatening in the first degree (both under the Alford doctrine), and intimidation based on bigotry or bias in the third degree. The remaining charges were nolled.In the Superior Court for the judicial district of New Britain, the defendant entered his pleas. The trial court conducted a plea canvass, accepted the pleas, and later denied the defendant’s motion to withdraw them, in which he argued that the canvass was constitutionally deficient because the court did not specifically confirm that he was knowingly waiving his rights to a jury trial, to confront accusers, and against self-incrimination. On appeal, the Appellate Court affirmed the trial court’s judgment, holding that the plea canvass was sufficient under Boykin v. Alabama, as the record did not presume a waiver from silence and demonstrated the defendant’s understanding of the rights he was waiving.The Connecticut Supreme Court reviewed the case and affirmed the Appellate Court’s judgment. It held that Boykin does not require an express advisement or enumeration of each constitutional right during a plea canvass. Rather, the totality of the circumstances must show that the plea was made knowingly and voluntarily. Here, the defendant’s responses, counsel’s statements, and the overall canvass were constitutionally adequate, though barely so, and the plea was valid. View "State v. Roberts" on Justia Law

The case involves a dispute between a credit union and borrowers who defaulted on a retail installment contract for a vehicle. After the borrowers defaulted, the credit union repossessed and sold the vehicle, then sued the borrowers for the remaining balance. The borrowers responded with a counterclaim alleging that the credit union failed to provide proper notice before and after repossession and sale, in violation of the Uniform Commercial Code (UCC) Article 9 and the Retail Installment Sales Financing Act (RISFA). The borrowers sought statutory damages under both statutes and also moved to certify their counterclaim as a class action.The Superior Court, Judicial District of Waterbury, granted summary judgment to the credit union on the borrowers’ counterclaim, reasoning that both the UCC and RISFA claims were subject to the one-year statute of limitations for penal statutes found in Connecticut General Statutes § 52-585. The court found the claims time-barred because they were filed more than one year after the alleged violations. Based on this conclusion, the court also denied the borrowers’ motion for class certification.On appeal, the Supreme Court of Connecticut concluded that the trial court applied the wrong statute of limitations. The Supreme Court held that both the UCC Article 9 and RISFA provisions at issue are remedial, not penal, and are thus not governed by the one-year limitation for penal statutes. Instead, it determined that the three-year statute of limitations for tort actions under § 52-577 applies, because the borrowers’ counterclaims arose from statutory violations rather than breach of contract. The Supreme Court reversed the trial court’s summary judgment and remanded the case for further proceedings, instructing the lower court to apply the three-year limitation and reconsider class certification. View "Connex Credit Union v. Madgic" on Justia Law

The plaintiffs, including a state commission and two tenants, alleged that the owner and management of an apartment complex discriminated against them by refusing to allow two emotional support dogs, despite a general no-pet policy. The tenants had previously lived at another complex that allowed both dogs as emotional support animals. Upon applying to the new complex, they provided documentation for the accommodation, but the defendants only approved one dog and requested further justification for the second. After the tenants objected to the additional requests, the defendants cancelled their lease and refunded their payments. The tenants subsequently found other housing.The Superior Court found for the plaintiffs, holding that the defendants had discriminated against the tenants by constructively denying their request for a reasonable accommodation, in violation of Connecticut's fair housing law. The court determined that the tenants had established the required elements for a failure-to-accommodate claim, specifically finding that one plaintiff was “regarded as” having a mental disability by the defendants.The defendants appealed to the Connecticut Appellate Court, which reversed the trial court’s judgment. The Appellate Court found that, although the plaintiff was regarded as having a disability, there was insufficient proof that the second dog was necessary for equal use and enjoyment of the dwelling. The Appellate Court also interpreted the trial court’s findings as implicitly determining that the plaintiff had a "record of" a disability.On further appeal, the Connecticut Supreme Court affirmed the reversal of the trial court’s judgment but vacated portions of the Appellate Court’s decision that addressed whether there was a “record of” disability and the legal standard for “necessity” of an accommodation. The Connecticut Supreme Court held that, because the trial court only found the plaintiff was "regarded as" having a disability, she was not entitled to a reasonable accommodation. View "Commission on Human Rights & Opportunities ex rel. Pizzoferrato v. Mansions, LLC" on Justia Law