Justia Connecticut Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the appellate court affirming the judgment of the trial court denying Defendant's motion to open the judgment in this marital dissolution case on the basis of fraud, holding that the appellate court properly affirmed the trial court's denial of Defendant's motion to open.Following a trial, the dissolution court issued a decision dissolving the parties' marriage and issuing certain financial orders. Defendant later filed this motion claiming that Plaintiff had committed fraud by denying the existence of a sexual relationship with another man during the course of the marriage and by testifying that Defendant had physically assaulted her. The trial court denied the motion, and the appellate court affirmed. The Supreme Court affirmed, holding that there was no abuse of discretion in the denial of Defendant's motion to open. View "Conroy v. Idlibi" on Justia Law

In this personal injury action, the Supreme Court reversed the judgment of the appellate court reversing the judgment of the trial court granting the joint motion for additurs filed by Plaintiffs and awarding each plaintiff additional money for pain and damages, holding that the trial court did not abuse its discretion by granting Plaintiffs' joint motion for additurs.Plaintiffs, William Maldonado and Geovanni Hernandez, filed a negligence action against Defendants after a car accident. The jury returned a verdict in favor of Plaintiffs and awarded economic damages in the amount of $17,228 to Maldonado and $11,864 to Hernandez but declined to award noneconomic damages. The trial court granted Plaintiffs' motion for additurs, concluding that the jury verdict was inherently inconsistent and awarding past economic damages in the amount of $8000 to Maldonado and $6500 to Hernandez. The Supreme Court reversed, holding (1) the trial court's explanation of the basis for the additur award was sufficient; and (2) the trial court did not abuse its discretion by granting Plaintiffs' joint motion for additurs. View "Maldonado v. Flannery" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the trial court in this case arising from allegations of sexual harassment brought by the complainant, a judicial marshal who was employed by the Connecticut Judicial Branch, holding that remand was required.A human rights referee with the Commission on Human Rights and Opportunities concluded that the the allegations were substantiated and awarded the complainant back pay, emotional distress damages, injunctive relief, and attorney's fees. The trial court reversed in part, concluding that the award of emotional distress damages must be vacated due to the complainant's failure to comply with discovery requests and that the injunction reinstating the complainant to her former workplace must be vacated as overbroad. The Supreme Court affirmed in part and reversed in part, holding that the trial court (1) properly concluded that emotional distress damages and attorney's fees were available remedies; but (2) erred in upholding the referee's determination that the state waived its sovereign immunity with respect to prejudgment and post judgment interest awards for civil rights violations. View "Connecticut Judicial Branch v. Gilbert" on Justia Law

The Supreme Court reversed the judgment of the trial court reversing the decision of the Board of Firearms Permit Examiners ordering the issuance of a pistol permit to Defendant, holding that the Board did not abuse its discretion in finding that Defendant was suitable to obtain a pistol permit in Connecticut.While Conn. Gen. Stat. 29-28(b) prohibits the issuance of a permit to carry a pistol or revolver if the applicant has been convicted of a felony or certain enumerated offenses it contains no language prohibiting the issuance of a permit based on out-of-state, nonfelony convictions. Defendant in this case appealed the judgment of the trial court reading section 29-28(b)(2)(B) to include extraterritorial misdemeanor convictions. The Supreme Court reversed, holding that the trial court improperly substituted its judgment for the Board that Defendant was a suitable person to obtain a pistol permit. View "Stratford Police Department v. Board of Firearms Permit Examiners" on Justia Law

The Supreme Court reversed in part the judgment of the trial court in this action alleging housing discrimination, holding that the court's ultimate conclusion as to liability on the facts of this case was clearly erroneous with respect to Sarah Henry, a licensed real estate salesperson.Plaintiff brought this complaint against several real estate defendants, alleging housing discrimination. The trial court rendered judgment in favor of Defendants, concluding that Plaintiff failed to prove that Defendants had discriminated against her. Plaintiff appealed, arguing that the trial court improperly considered whether Henry had the subjective intent to discriminate when she made certain statements. The Supreme Court reversed in part, holding (1) the trial court applied the proper legal standard in considering Plaintiff's claims under Conn. Gen. Stat. 46a-64c(a)(3); but (2) the trial court's finding that Henry's statements did not convey a discriminatory message to an ordinary listener was clearly erroneous. View "Lopez v. William Raveis Real Estate, Inc." on Justia Law

The Supreme Court reversed the judgment of the appellate court affirming the decision of the habeas court dismissing Petitioner's petition for a writ of habeas corpus as barred by a procedural default, holding that Petitioner's pleadings met the standard necessary to survive a motion to dismiss.Petitioner was found guilty by a jury of sexual assault in the first degree and risk of injury to a child. In the instant case, Petitioner sought a second writ of habeas corpus, alleging that he suffered from severe intellectual disabilities and mental health afflictions at the time of trial and that he was denied due process because he was incompetent to be prosecuted and to stand trial. The habeas court dismissed the petition on the ground that Petitioner's due process claims were procedurally defaulted. The appellate court affirmed. The Supreme Court reversed, holding (1) Petitioner was not precluded from raising a freestanding competency claim; and (2) the habeas court erred in finding that Petitioner failed to allege sufficient prejudice to survive a motion to dismiss. View "Saunders v. Commissioner of Correction" on Justia Law

The Supreme Court affirmed the judgment of the appellate court affirming Defendant's conviction of murder, holding that the appellate court did not err.On appeal, the appellate court concluded that the trial court had not abused its discretion in joining Defendant's case with the codefendant's case and that Defendant's right to confrontation was not violated when the trial court allowed a state's firearms examiner to testify about the findings of a second firearms examiner. The Supreme Court affirmed, holding (1) the appellate court did not err in determining that the trial court's joinder of Defendant's and his codefendant's cases was proper; (2) the admission of CSLI information into evidence was not error; and (3) the appellate court did not err by not determining that Defendant's right to confrontation was not violated by the challenged testimony, but the violation was harmless beyond a reasonable doubt. View "State v. Tyus" on Justia Law

The Supreme Court reversed in part the judgment of the trial court awarding damages in favor of Plaintiff in this action seeking compensatory and punitive damages for breach of a partnership agreement, breach of fiduciary duty, and libel per se, holding that the trial court erred with respect to the libel claim.A jury found in favor of Plaintiff on all three counts and awarded him both compensatory and punitive damages. On appeal, Defendant argued that the trial court erred by denying his motions to set aside the verdict and for judgment notwithstanding the verdict. The Supreme Court reversed in part, holding (1) Plaintiff's claims were not barred by the compulsory counterclaim rule set forth in Fed. R. Civ. P. 13(a)(1); (2) Plaintiff's breach of partnership agreement and breach of fiduciary duty claims did not fail as a matter of law under Karanian v. Maulucci, 440 A.2d 959 (Conn. 1981); and (3) with respect to the libel claim, the trial court erred by admitting the testimony of Plaintiff's expert witness on damages because there was no evidence to support the testimony. View "Chugh v. Kalra" on Justia Law

The Supreme Court affirmed the judgment of the habeas court denying in part Petitioner's petition for a writ of habeas corpus, holding that the habeas court correctly concluded that Petitioner did not demonstrate that he had suffered prejudice from the ineffective assistance of his trial counsel.Petitioner, a citizen of Jamaica who held a valid green card, pleaded guilty, pursuant to the Alford doctrine, to risk of injury to a child and strangulation in the third degree. The federal government subsequently initiated removal proceedings against Petitioner based, in part, on his conviction of risk of injury to a child. Petitioner filed a petition for a writ of habeas corpus, alleging ineffective assistance of counsel alleging that he would have gone to trial had his trial counsel not performed deficiently. The habeas court denied the petition as to the claim at issue in this appeal. The Supreme Court affirmed, holding that Petitioner did not meet his burden of establishing that there was a reasonable probability that he would have rejected the plea offer and proceeded to trial. View "Grant v. Commissioner of Correction" on Justia Law

The Supreme Court reversed the judgment of the appellate court affirming the trial court's dismissal of this appeal from the decision of the Planning and Zoning Commission of the Town of Bethel denying Plaintiffs' application for a special permit to construct a crematory on their property, holding that the denial was not supported by substantial evidence.Plaintiffs applied for a special permit to construct a crematory on their property. The Commission denied the application. Relying on St. Joseph's High School, Inc. v. Planning & Zoning Commission, 170 A.3d 73 (Conn. 2017), the trial court dismissed Plaintiff's ensuing appeal, concluding that there was substantial evidence to support the Commission's decision. The appellate court affirmed. The Supreme Court reversed, holding that the record did not reveal substantial evidence on which the Commission based its decision. View "McLoughlin v. Planning & Zoning Commission" on Justia Law