Justia Connecticut Supreme Court Opinion Summaries

The case involves a defendant who was charged with two counts of sexual assault in the first degree and two counts of risk of injury to a child, stemming from two separate incidents. The first incident involved his biological daughter between October 2020 and June 2021 when she was approximately eight to nine years old. The second involved his former girlfriend’s daughter in 2011 or 2012, when that child was about eight years old. In both instances, the allegations centered on inappropriate sexual conduct by the defendant, with both victims eventually disclosing the abuse years after the events occurred.Prior to trial in the Superior Court in the judicial district of New Haven, the State moved to join the two cases for a single trial, arguing the evidence was cross-admissible and that joinder was supported by established factors. The trial court granted the motion for joinder. At trial, an expert witness testified about the behavioral characteristics of child sexual abuse victims and the concept of “grooming” through responses to hypothetical questions based on the facts of the case. Defense counsel objected, claiming this testimony improperly bolstered the victims’ credibility, but the court overruled the objection. The jury found the defendant guilty on all counts and he was sentenced accordingly.On direct appeal to the Connecticut Supreme Court, the defendant argued that the trial court had applied the wrong legal standard in granting joinder, and had abused its discretion by allowing the expert’s testimony in response to the hypotheticals. The Supreme Court held that the trial court had applied the correct legal standard and properly placed the burden on the state to justify joinder. The court also concluded that the expert’s testimony, given in general or hypothetical terms without direct reference to the complainants, was permissible and did not amount to improper vouching. The convictions were affirmed. View "State v. Lawrence M." on Justia Law

The plaintiff was involved in a motor vehicle accident with the defendant. After the accident, the plaintiff’s insurer, Nationwide, accepted a $25,000 payment from the defendant’s insurer, State Farm, which exhausted the property damage liability limits of the defendant’s policy. The plaintiff had not yet been fully compensated for his claimed damages, including diminution in value and loss of use of his vehicle. He alleged that Nationwide’s acceptance of the funds violated his rights under the make whole doctrine, which holds that an insurer may not enforce its subrogation rights until the insured has been fully compensated for their loss.In the Superior Court for the judicial district of Hartford, the plaintiff brought a negligence claim against the defendant and an unjust enrichment claim against Nationwide. The trial court dismissed the unjust enrichment claim as unripe, reasoning that the plaintiff’s right to relief depended on the outcome of his negligence claim against the defendant, the amount of his damages, and whether the defendant could satisfy any potential judgment. The Appellate Court affirmed, finding that the claim was contingent upon the plaintiff first obtaining a judgment against the defendant and the defendant’s inability to satisfy that judgment.The Supreme Court of Connecticut reviewed the case and held that the Appellate Court erred in upholding the dismissal on ripeness grounds. The Court determined that, under the make whole doctrine, an insured’s cause of action for wrongful subrogation is ripe before a judgment is obtained against the tortfeasor. The plaintiff’s alleged injury—loss of priority to available insurance proceeds—was not hypothetical because Nationwide’s subrogation had already depleted the funds. The Court also rejected the argument that the plaintiff lacked standing, finding a sufficient personal and legal interest at stake. The Supreme Court reversed the Appellate Court’s judgment and remanded for further proceedings. View "Orlando v. Liburd" on Justia Law

The case concerns an incident in which the defendant unlawfully entered a West Hartford residence where several individuals were present, including his ex-girlfriend and her new partner. The defendant shot the new partner in the face and threatened others before fleeing. He was apprehended shortly afterward, and gunshot residue was found on his hand. The prosecution charged him with multiple counts, including first-degree assault with a firearm, home invasion, criminal possession of a firearm, threatening, and risk of injury to a child. At trial, the defense argued that a third party was responsible for the shooting, but the jury found the defendant guilty on all counts.Prior to this appeal, the Superior Court in the judicial district of Hartford presided over the trial and delivered the conviction. The operative information charged the defendant with home invasion under the general statute but described conduct that aligned with committing a felony (assault) during the invasion. However, the trial court instructed the jury using a different statutory subdivision, focusing on whether the defendant was armed with a deadly weapon during the home invasion. The defense did not object to the home invasion instruction at trial.On direct appeal to the Connecticut Supreme Court, the defendant argued that his Sixth Amendment right to notice was violated because the jury was instructed on a statutory theory not specifically charged, and that his convictions for both home invasion and first-degree assault violated the double jeopardy clause. The Connecticut Supreme Court held that there was no plain error in the jury instruction, finding the information provided adequate notice for conviction under either statutory subdivision, and that the defense was not prejudiced. The Court further held that the convictions did not violate double jeopardy, as each offense required proof of an element the other did not. The judgment of conviction was affirmed. View "State v. Christon M." on Justia Law

The case concerns a man convicted of conspiracy to commit robbery in the first degree, attempt to commit robbery in the first degree, and assault in the first degree after a pizza delivery driver was shot. The prosecution’s theory was that the defendant, while visiting a friend, used that friend’s cell phone to place calls to restaurants to target a delivery driver for robbery. A key witness, the friend, testified that the defendant used his phone to order the pizza, and a detective corroborated that the phone was used to call the pizza restaurant. The defense argued that the friend, not the defendant, committed the offenses, and the defendant also presented an alibi defense.Following his conviction, the defendant filed a habeas petition in the Superior Court for the judicial district of Tolland, alleging ineffective assistance of counsel due to his trial counsel’s failure to investigate the friend’s cell phone records and to present additional alibi witnesses. The habeas court denied relief, and the Appellate Court affirmed. While the Appellate Court agreed that counsel’s performance regarding the phone records was deficient, a majority found no prejudice, reasoning that the outcome would not have changed. A dissenting judge disagreed, finding that the phone records could have undermined key testimony.The Supreme Court of Connecticut reviewed the case and held that the Appellate Court erred in concluding that the defendant failed to establish prejudice from counsel’s failure to investigate and present the phone records. The Supreme Court found a reasonable probability that the outcome would have differed had the records been introduced, as they would have seriously undermined the prosecution’s case and supported the defense theory. The Supreme Court reversed the Appellate Court’s judgment and directed that the habeas court grant the petition, vacate the convictions, and order a new trial. View "Grant v. Commissioner of Correction" on Justia Law

The defendant was convicted of five counts of sexual assault in the first degree and two counts of risk of injury to a child, based on multiple incidents of sexual abuse against two minor victims who attended a day care operated by the defendant’s wife in their home. The abuse occurred over several years, when the victims were between three and eight years old. The state’s case relied on evidence that the defendant committed a variety of sexual acts against each child on separate occasions. Each count of sexual assault was based on multiple, distinct incidents involving a specific sexual act.The Superior Court for the judicial district of New Haven conducted a jury trial. At the conclusion of evidence, the trial court provided the jury with specific unanimity instructions for each count, stating that to find the defendant guilty, all jurors must unanimously agree that the defendant committed at least one specific alleged act described in the count. The jury returned guilty verdicts on all counts, and the court sentenced the defendant to a total effective term of twenty-five years’ imprisonment, execution suspended after twenty-one years, followed by ten years of probation. The defendant appealed directly to the Connecticut Supreme Court, arguing his right to a unanimous jury verdict was violated because the trial court did not require the jury to answer special interrogatories identifying which incident formed the basis for each conviction.The Supreme Court of Connecticut held that the federal constitution does not require special interrogatories on unanimity in addition to a specific unanimity instruction when a single count is based on multiple, separate acts. The Court found the trial court’s unanimity instructions sufficient to protect the defendant’s constitutional rights and affirmed the judgments. View "State v. Carlos G." on Justia Law

A fire at a call center in Davao City, Philippines, resulted in the deaths of twenty-nine individuals who were employees of a Philippine company providing services for a Connecticut-based company. The estates of the deceased and other plaintiffs, most of whom were Philippine citizens or residents, brought a wrongful death and loss of consortium action in Connecticut against the Connecticut company and two of its officers, who were also involved with the Philippine employer.The Superior Court, Complex Litigation Docket, granted the defendants’ motion to dismiss on the ground of forum non conveniens, finding the Philippines to be an adequate alternative forum. The court considered conflicting affidavits from expert witnesses regarding whether Philippine courts would accept the case, given concerns about the statute of limitations. The dismissal was conditioned on allowing the plaintiffs to reinstate the Connecticut action if the Philippine courts declined jurisdiction. The Appellate Court affirmed this decision, concluding that the trial court applied the proper legal standard and meaningfully assessed the adequacy of the Philippine forum.On further appeal, the Connecticut Supreme Court affirmed the Appellate Court’s judgment. It held that the trial court correctly applied the legal standard from Picketts v. International Playtex, Inc., and undertook a meaningful assessment of the adequacy of the Philippines as an alternative forum. The Supreme Court found that the trial court did not rely solely on the defendants’ consent to jurisdiction but weighed competing affidavits and evidence regarding Philippine law and procedure. The conditional nature of the dismissal, allowing reinstatement in Connecticut if the Philippine courts declined jurisdiction, was also deemed appropriate. Thus, the disposition by the Connecticut Supreme Court was to affirm the Appellate Court’s decision. View "DeCicco v. Dynata, LLC" on Justia Law

The case concerned a man charged with murder, burglary, conspiracy, and tampering with evidence after the decomposed body of a woman with whom he had an intimate relationship was discovered. The investigation revealed that he and his girlfriend devised and executed a plan to kill the woman, subsequently disposing of her body and attempting to destroy evidence. The defendant was interviewed by police on three occasions. During the second interview, after waiving his Miranda rights, he made incriminating statements and then invoked his right to remain silent. The next morning, while awaiting arraignment, the defendant initiated a third interview, during which he made an equivocal reference to counsel, received renewed Miranda warnings, and then confessed.The Superior Court for the judicial district of Waterbury denied the defendant’s motion to suppress statements from the third interview and his cell phone records. The jury found the defendant guilty of murder, burglary, conspiracy to commit burglary, and tampering with evidence; the court vacated the conspiracy to commit tampering conviction at sentencing. The defendant appealed directly to the Connecticut Supreme Court, arguing that the trial court improperly admitted his September 23 interview (second interview), failed to suppress the September 24 interview confession (third interview), and wrongly admitted his cell phone records.The Supreme Court of Connecticut affirmed the trial court’s judgment. It held that defense counsel had affirmatively waived any Miranda-based challenge to the September 23 interview. Regarding the September 24 interview, the Court concluded that the detective’s renewed Miranda advisement adequately clarified the defendant’s equivocal request for counsel, and his written waiver manifested a clear desire to proceed without counsel. The Court also held that the search warrant for cell phone records was supported by probable cause, was sufficiently particular, and did not authorize a general search. The defendant’s additional constitutional claims were also rejected. View "State v. Johnson" on Justia Law

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