Justia Connecticut Supreme Court Opinion Summaries

The Supreme Court denied Petitioner's petition for certification to appeal the appellate court's dismissal of his appeal from the judgment of the habeas court declining to issue a writ of habeas corpus, holding that the habeas court did not abuse its discretion in denying certification to appeal.Petitioner filed a petition for a writ of habeas corpus challenging his conviction of sexual assault in the second degree. The habeas court declined to issue the writ on the ground that Petitioner was not in the custody of the Commissioner of Correction. Thereafter, Petitioner filed a petition for certification to appeal, which the habeas court denied. The appellate court dismissed Petitioner's appeal on the ground that he failed in his appellate court brief to brief the claim that the habeas court had abused its discretion in denying his petition for certification to appeal. The Supreme Court affirmed, holding that a petition must at least expressly allege and explain in his brief how the habeas court abused its discretion in denying certification. View "Goguen v. Commissioner of Correction" on Justia Law

The Supreme Court affirmed the judgment of the trial court in favor of Defendants in this action alleging that Boston Scientific Corporation's sale of its Obtryx Transobturator Mid-Urethral Sling System (Obtryx) violated the Connecticut Product Liability Act, Conn. Gen. Stat. 52-572m et seq., holding that there was no error.The named plaintiff alleged that the Obtryx, a transvaginal mesh sling implanted in women to treat stress urinary incontinence, injured her in various ways after it was implanted in her. Plaintiffs brought claims against Boston Scientific and the named plaintiff's gynecologist and medical practice, alleging violations of the Act, negligence sounding in informed consent, and misrepresentation. The trial court granted the medical defendants' motion for summary judgment. The case proceeded to trial against Boston Scientific, and the jury returned a verdict in its favor. The Supreme Court affirmed, holding that the trial court (1) did not err in granting summary judgment for the medical defendants on the informed consent and misrepresentation claims; and (2) properly declined to instruct the jury on the reasonable alternative design prong of the risk-utility test. View "Fajardo v. Boston Scientific Corp." on Justia Law

The Supreme Court upheld the decision of the trial court denying Plaintiff's application for a civil protection order, holding that Plaintiff's claims on appeal lacked merit.At issue before the Supreme Court was the standard courts must apply to determine whether an applicant for a civil protection order has established the element of fear. On appeal from the denial of her application for a civil protection order Plaintiff argued, among other things, that the trial court improperly interpreted Conn. Gen. Stat. 46b-16a as creating a subjective-objective standard for establishing fear rather than a purely objective standard. The Supreme Court affirmed, holding (1) the trial court properly interpreted section 46b-16a; (2) none of the trial court's factual findings was clearly erroneous; and (3) section 46b-16a does not violate the equal protection clause of the Connecticut constitution. View "L.H.-S. v. N.B." on Justia Law

The Supreme Court affirmed the decision of the trial court affirming the judgment of the probate court that Peter Ziegler's Yellow Submarine Trust was a permissible appointee, holding that an unfunded charitable trust is a permissible appointee of the exercise of a nongeneral testamentary power of appointment.In 2015, Peter, a member of a wealthy Connecticut family, suffered an accident rendering him a quadriplegic. One year later, Peter executed a trust instrument to create his Yellow Submarine Trust, which was not funded during Peter's lifetime. Peter, who had nongeneral testamentary powers of appointment under various family trusts, did exercise his powers of appointment in his will to direct the proceeds of the sale of stock in his family's corporation to his Yellow Submarine Trust. Peter's sister argued that the trust was an impermissible appointee because it was unfunded during Peter's lifetime. The probate court disagreed, and the trial court affirmed. The Supreme Court affirmed, holding that Peter's Yellow Submarine Trust was a permissible appointee even though it was not funded prior to Peter's death. View "Benjamin v. Corasaniti" on Justia Law

The Supreme Court reversed the judgment of the appellate court affirming the trial court's judgment of strict foreclosure, holding that the appellate court erred in holding that noncompliance with federal Department of Housing and Urban Development (HUD) regulations is a special defense that Defendant must plead and prove and that the case must be remanded for a trial.Defendant executed a mortgage in a mortgage deed that were guaranteed and/or insured by the Federal Housing Administration (FHA) and ultimately assigned to Plaintiff. Under the terms of the mortgage deed and note, Plaintiff was not authorized to accelerate payment of the debt or to initiate foreclosure proceedings unless permitted by HUD regulations. After Defendants defaulted on the note and mortgage the trial court entered a judgment of strict foreclosure. The appellate court affirmed. The Supreme Court reversed, holding (1) compliance with applicable HUD regulations is a condition precedent to enforcement of the note and foreclosure of the mortgage and must be pleaded and ultimately proved by the mortgagee; and (2) the trial court erred by failing to require Plaintiff to establish compliance with HUD regulations at trial. View "Wells Fargo Bank, N.A. v. Lorson" on Justia Law

The Supreme Court affirmed the judgment of the trial court concluding that enforcement of the prenuptial agreement between the parties was not unconscionable, with one exception, holding that the trial court did not err in ruling that the occurrence of the unforeseen events did not render the enforcement of the entire agreement unconscionable at the time of the dissolution.In 2010, shortly before the parties' marriage they executed a prenuptial agreement. In 2016, Plaintiff brought this action seeking dissolution of the marriage and enforcement of the prenuptial agreement. Defendant filed a cross-claim, asserting that the agreement was unenforceable because it was unconscionable at the time of the dissolution under Conn. Gen. Stat. 46b-36g(a)(2). The trial court dissolved the marriage and enforced the terms of the prenuptial agreement with the exception of an attorney's fees provision. The Supreme Court affirmed, holding that the trial court properly allowed the parties the benefit of their agreed-upon, pre-marriage bargain. View "Grabe v. Hokin" on Justia Law

The Supreme Court affirmed Defendant's convictions of manslaughter in the first degree with a firearm and criminal possession of a firearm, holding that the trial court did not err or abuse its discretion.During his first trial, the jury found Defendant guilty of murder but rejected his claim of self-defense. Defendant was found guilty of criminal possession of a firearm in a subsequent trial in connection with the same incident. The Supreme Court affirmed, holding (1) the evidence was sufficient to disprove Defendant's claim of self-defense beyond a reasonable doubt; and (2) the trial court correctly concluded that any juror misconduct caused no actual prejudice to Defendant and thus did not err in denying Defendant's motion for a new trial. View "State v. Hughes" on Justia Law

The Supreme Court affirmed the order of the trial court ordering a foreclosure by sale as to two parcels of land owned by Defendants and secured by a blanket mortgage given to Plaintiff, holding that there was no error in the trial court's order of foreclosure by sale.The mortgage agreement between the parties contained a remedies provision providing that Plaintiff could seek a foreclosure by sale as to two parcels of land in the events Defendants defaulted on the mortgage. The trial court determined that the remedies provision was not binding on the court but, in its balancing of equities, considered the remedies provision as one factor. The Supreme Court affirmed, holding that the trial court did not abuse its discretion by ordering a foreclosure by sale. View "Toro Credit Co. v. Zeytoonjian" on Justia Law

The Supreme Court affirmed the judgment of the appellate court remanding this case to the trial court with direction to render judgment in favor of Defendant on Plaintiff's negligence claim that had previously been the subject of mandatory arbitration in a prior civil action, holding that the appellate court's decision was not in error.Plaintiff brought a personal injury action against Defendant in 2015. Before trial, the parties attended arbitration, and the arbitration found in favor of Defendant. The trial court entered judgment in accordance with the arbitrator's decision. Plaintiff then brought the instant action repeating the allegations of negligence in the first action. The trial court granted Defendant's motion to dismiss on the basis of res judicata. The appellate court affirmed on different grounds, concluding that action was not viable because the action had been tried on its merits by the arbitrator and had resulted in a judgment in favor of Defendant. The Supreme Court affirmed, holding that appellate court did not err. View "Larmel v. Metro North Commuter Railroad Co." on Justia Law

The Supreme Court affirmed the judgment of the appellate court affirming Defendant's conviction of felony murder, holding that there was no error.On appeal, Defendant argued that the trial court erred in admitting testimony regarding the gang affiliations of Defendant and the State's relocation of the State's chief witness after the witness provided information to the police incriminating Defendant in the murder. Defendant further challenged other rulings involving the chief witness. The Supreme Court affirmed the appellate court's judgment denying Defendant's appeal, holding that the appellate court did not err in its resolution of the case. View "State v. Bermudez" on Justia Law