Justia Connecticut Supreme Court Opinion Summaries

The Supreme Court reversed in part the decision of the appellate court affirming the order of the trial court rendering summary judgment in favor of Defendants in a tort action on the grounds that the claims were barred by the doctrine of collateral estoppel, holding that no preclusion doctrine barred Plaintiff from litigating her tortious interference with contractual relations claim.Plaintiff alleged that Defendants tortiously interfered with her contractual relations and right of inheritance by exercising undue influence over her husband, the decent, with respect to a proposed amendment to an antenuptial agreement and a testamentary will. The trial court entered summary judgment for Defendants, ruling that the doctrine of collateral estoppel barred both of Plaintiff's tortious interference claims. The appellate court affirmed. The Supreme Court reversed in part, holding (1) under the circumstances of this case, Plaintiff's claim for tortious interference with contractual relations was not precluded; and (2) Plaintiff was collaterally estopped from relitigating her tortious interference with a right of inheritance claim. View "Solon v. Slater" on Justia Law

The Supreme Court affirmed the judgment of the trial court denying Defendant's motion to suppress statements he had made during two separately recorded interrogations of him by police officers, holding that the trial court properly denied Defendant's motion to suppress.The two interrogations at issue occurred on the same day. As to the first interrogation, Defendant claimed that the police failed to advise him of his rights pursuant to Miranda v. Arizona, 384 U.S. 436 (1966). Defendant further claimed that the second interrogation was tainted by the alleged illegality of the first interrogation. The trial court denied the motion to suppress and, following a jury trial, convicted Defendant of manslaughter in the first degree with a firearm. The Supreme Court affirmed, holding (1) Miranda warnings were not required for the first interrogation because it was not custodial; and (2) the failure to provide the warnings did not taint the second interrogation. View "State v. Brandon" on Justia Law

The Supreme Court affirmed the judgment of the habeas court denying Petitioner's petition for a writ of habeas corpus, holding that Petitioner failed to establish that he was entitled to relief.Petitioner was convicted of manslaughter in the first degree with a firearm, assault in the first degree, and criminal possession of a firearm. In his habeas petition, Petitioner argued that his trial counsel's concession of Petitioner's guilt to the manslaughter charge without Petitioner's prior approval violated his rights to effective assistance of counsel under Strickland v. Washington, 466 U.S. 668 (1984), and personal autonomy under McCoy v. Louisiana, __ U.S. __ (2018). The habeas court denied the petition, finding Petitioner's claims to be without merit. The Supreme Court affirmed, holding (1) the habeas court correctly determined that Petitioner's right to autonomy was not implicated under the facts of this case; and (2) Petitioner's second claim on appeal was unpreserved. View "Grant v. Commissioner of Correction" on Justia Law

The Supreme Court reversed the judgment of the appellate court affirming the decision of the trial court to deny Defendant's motion to open the judgment and vacated the trial court's judgment of foreclosure by sale in favor of Plaintiff, The Bank of New York Mellon, holding that the appellate court erred.The trial court concluded that Defendant's motion to open constituted a collateral attack on an earlier judgment. Defendant appealed, arguing that Plaintiff lacked standing to pursue foreclosure, and thus, the trial court lacked jurisdiction over the action. The appellate court disagreed, concluding that Defendant's motion to open constituted an impermissible collateral attack on the foreclosure judgment. The Supreme Court reversed and remanded the case, holding that the appellate court (1) erroneously concluded that Defendant's motion to open was a collateral attack because, at the time Defendant filed his motion to open, the trial court had jurisdiction to open the judgment under Neb. Rev. Stat. 52-212a; and (2) this Court rejects the alternative ground that the trial court properly denied Defendant's motion to open in which he claimed that the trial court lacked subject matter jurisdiction. View "Bank of New York Mellon v. Tope" on Justia Law

The Supreme Court affirmed the judgment of the trial court joining for trial, pursuant to Practice Book 41-19, sexual assault, risk of injury to a child, and strangulation charges with threatening and disorderly conduct charges, holding that the trial court did not err or abuse its discretion.Specifically, the Supreme Court held that the trial court did not abuse its discretion when it (1) joined the sexual assault cases and the threatening and disorderly conduct cases for trial; and (2) denied Defendant's request, as a remedy for the disclosure of his prior incarceration by one of the state’s witnesses, that he be allowed to testify about the nonsexual nature of his prior felony convictions without opening the door to being asked on cross-examination about the nature of those convictions. View "State v. James A." on Justia Law

The Supreme Court reversed in part the judgment of the appellate court affirming Defendant's conviction of sexual assault in the first degree, risk of injury to a child, and conspiracy to commit risk of injury to a child, holding that the case must be remanded to the trial court for a new trial on the sexual assault count.On appeal from his convictions, Defendant argued that each count was duplicitous because each count charged him with a single violation of the underlying statute when the evidence established multiple, separate incidents of conduct and, consequently, the court's failure to either grant his request for a bill of particulars or a specific unanimity instruction violated his constitutional right to jury unanimity. The Supreme Court reversed in part, holding (1) count two, charging the defendant with a single violation of Conn. Stat. Ann. § 53-21 (a) (2), was not duplicitous, and thus the trial court’s failure to grant the defendant’s request for a specific unanimity instruction or a bill of particulars as to that count did not violate his constitutional right to jury unanimity; and (2) Defendant was not entitled to reversal of his remaining convictions. View "State v. Joseph V." on Justia Law

The Supreme Court affirmed the judgment of the appellate court upholding Defendant's conviction of five counts of risk of injury to a child, holding that the trial court properly declined to give the jury a specific unanimity instructions as to counts one, five, and six.During trial, defense counsel requested that the court provide a specific unanimity instruction as to the counts at issue on appeal because the evidence showed there were discrete incidents, not a continuing course of conduct. The court declined to give the instruction. On appeal, Defendant argued that counts one, five, and six were duplicitous because each count charged him with a single violation of Conn. Rev. Stat. 53-21(a)(2). The Supreme Court affirmed, holding that, from the evidence, the jury reasonably could have found that Defendant's criminal acts constituted a single criminal episode and thus did not constitute multiple, separate incidents of conduct under the applicable test. View "State v. Douglas C." on Justia Law

The Supreme Court reversed the judgment of the trial court with respect to the count of risk of injury to a child pertaining to one of the complainants and otherwise affirmed Defendant's conviction of several counts of sexual assault, holding that the evidence presented at trial was sufficient to support the remaining convictions.Defendant was convicted of several counts of attempt to commit sexual assault in the first degree, sexual assault in the first degree, sexual assault in the second degree, and risk of injury to a child. On appeal, Defendant argued, among other things, that the evidence presented at trial was insufficient to support his conviction on certain counts. The Supreme Court reversed in part, holding (1) the evidence was insufficient to support Defendant's conviction for risk of injury to a child; and (2) the prosecutor's use of Defendant's prior misconduct was improper, but the jury's verdict would not have been different in the absence of that comment. View "State v. Gary S." on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of felony murder, with robbery in the third degree as the predicate felony and carrying a pistol or revolver without a permit, holding that Defendant was not entitled to relief on his allegations of error.On appeal, Defendant argued, among other things, that the prosecutor committed improprieties during closing argument by arguing facts that were not in evidence and by making inferences that were unsupported by the evidence. The Supreme Court affirmed, holding (1) there was sufficient evidence to support the conviction of felony murder with the predicate felony of third-degree robbery; and (2) the prosecutor did not engage in improprieties during closing argument that deprived Defendant of his due process right to a fair trial. View "State v. Brown" on Justia Law

The Supreme Court granted in part Defendant's petition for review of the trial court's denial of his motion for modification of the $20 million bond that was set in connection with murder charges against him, holding that remand was required for the trial court to consider Petitioner's request for a ten percent bail option pursuant to Practice Book 38-8.In his petition, Defendant argued that the bail amount was unreasonably high and that the trial court erroneously concluded that it lacked the authority to grant Defendant's request for a ten percent cash option. The Supreme Court remanded the case, holding (1) given the extraordinary flight risk and public safety considerations presented in this case, the trial court did not abuse its discretion in setting the bond amount at $20 million; and (2) the trial judge incorrectly concluded that he lacked discretion to offer Defendant a ten percent cash bail option under Practice Book 38-8. View "State v. Pan" on Justia Law