Justia Connecticut Supreme Court Opinion Summaries

A four-year-old child drowned after wandering unattended from the home where she had been placed under temporary custody by order of the Probate Court. The child’s parents had previously lost guardianship, and the court had vested temporary custody in maternal relatives. To determine whether to grant a full transfer of guardianship, the Probate Court ordered the Department of Children and Families (DCF) to investigate the home and report its findings. DCF submitted its report, recommending the placement, but before the court could hold a hearing on permanent guardianship, the child died. The child’s estate, through her father as administrator, alleged that DCF’s negligence in investigating the placement and in making recommendations to the Probate Court was a proximate cause of the child’s death, and also claimed DCF failed to fulfill independent duties to protect the child from abuse and neglect.After the estate received permission from the Claims Commissioner to sue the state, DCF moved to dismiss the action in the Superior Court, arguing that it was entitled to absolute quasi-judicial immunity for actions integral to the judicial process, such as conducting court-ordered investigations and making recommendations. The Superior Court agreed, holding that DCF was protected by absolute quasi-judicial immunity when acting as an arm of the Probate Court, and that the Claims Commissioner could not waive this immunity. The court dismissed the action, finding the complaint’s allegations insufficient to overcome DCF’s immunity.On appeal, the Connecticut Supreme Court held that the Claims Commissioner’s waiver of sovereign immunity under the relevant statute does not preclude the state from asserting absolute quasi-judicial immunity. However, the Court reversed in part, concluding that some of the estate’s allegations may fall outside the scope of quasi-judicial immunity, particularly those involving DCF’s independent statutory duties. The case was remanded for further proceedings to determine which claims, if any, are not barred by quasi-judicial immunity. View "Jamie G. v. Dept. of Children & Families" on Justia Law

An attorney in Connecticut discovered that his name and attorney registration number were being used by a criminal organization, believed to be based in Mexico, to defraud time-share owners in the United States and Canada. The organization created a sham website using the attorney’s identity to induce victims to transfer funds under false pretenses. The attorney learned of the scheme in 2019 and took steps to stop it, including contacting authorities and assisting in taking down the fraudulent website, though it repeatedly reappeared. The scam affected the attorney’s personal and professional life, causing significant emotional distress, and resulted in substantial losses to numerous victims.The attorney filed suit in the Superior Court, judicial district of Middlesex, seeking damages for identity theft under Connecticut law and for violations of the Connecticut Unfair Trade Practices Act (CUTPA). The defendants failed to appear, resulting in a default judgment. The trial court awarded the attorney $150,000 in compensatory damages for identity theft, $300,000 in punitive damages under CUTPA, as well as attorney’s fees and costs. The attorney moved for treble damages under the identity theft statute, but the trial court denied the motion without explanation.On appeal, the Connecticut Appellate Court determined that the attorney was entitled to treble damages under the identity theft statute, totaling $450,000, but held that he could not recover both treble damages and punitive damages under CUTPA for the same conduct, citing the rule against double recovery. The Appellate Court vacated the punitive damages award and directed the trial court to award only treble damages.The Connecticut Supreme Court reviewed the case and held that the attorney was entitled to both treble damages under the identity theft statute and punitive damages under CUTPA. The Court reasoned that the two remedies address different legal harms and are not duplicative. The Supreme Court reversed the Appellate Court’s judgment in part and directed reinstatement of the trial court’s punitive damages award under CUTPA. View "White v. FCW Law Offices" on Justia Law

A nonprofit substance abuse treatment facility in Kent, Connecticut, challenged the state’s approval of a competitor’s application to establish a similar facility in the same town. The competitor, Birch Hill Recovery Center, LLC, applied for a certificate of need from the Department of Public Health. The plaintiff was granted intervenor status in the administrative proceedings, allowing it to participate in hearings and present evidence. After public hearings, a hearing officer recommended denying Birch Hill’s application, but the Department and Birch Hill later entered into a settlement agreement that approved the application with certain conditions.The plaintiff appealed the Department’s decision to the Superior Court, arguing that the approval was an abuse of discretion, especially given the hearing officer’s earlier recommendation. The defendants moved to dismiss the appeal, contending that the plaintiff was not aggrieved by the decision and thus lacked standing. The Superior Court initially dismissed the appeal on the ground that the settlement agreement was not a final decision. The Appellate Court affirmed this dismissal. However, the Connecticut Supreme Court later held that the settlement agreement was a final decision and remanded the case for further proceedings. On remand, the Superior Court again dismissed the appeal, this time concluding that the plaintiff was not statutorily or classically aggrieved and therefore lacked standing.The Supreme Court of Connecticut affirmed the dismissal, holding that the plaintiff was neither statutorily nor classically aggrieved by the Department’s decision. The Court explained that mere economic competition resulting from governmental action does not confer standing in administrative appeals unless the relevant statute expressly protects competitors’ interests. The Court found that the applicable statute, General Statutes (Rev. to 2017) § 19a-639 (a), did not create such an exception. The plaintiff’s status as an intervenor and its participation in the administrative process did not, by themselves, establish a specific, personal, and legal interest sufficient for standing. View "High Watch Recovery Center, Inc. v. Dept. of Public Health" on Justia Law

The defendant was convicted of murder and various firearm offenses related to the shooting death of his neighbor. During a police interview, the defendant confessed to the shooting and discussed his struggles with homelessness and issues with his stepmother and the victim. He believed his stepmother and the victim were conspiring against him. At trial, the defendant claimed he acted under extreme emotional disturbance, but the jury rejected this defense.The trial court allowed the defendant's entire police interview into evidence, including parts where he used homophobic slurs, deeming it relevant to his emotional state. The jury found the defendant guilty of murder and other charges, and he was sentenced to forty-five years in prison.On appeal to the Connecticut Supreme Court, the defendant argued that prosecutorial impropriety during closing and rebuttal arguments deprived him of a fair trial. Specifically, he claimed the prosecutors misstated the law on extreme emotional disturbance, denigrated the defense, and invited jury nullification. The court found that the prosecutors did indeed misstate the law by suggesting the defendant's subjective beliefs did not matter and by improperly framing the reasonableness inquiry. These misstatements were central to the case and not cured by the trial court's instructions.The Connecticut Supreme Court concluded that the prosecutorial impropriety deprived the defendant of a fair trial, reversed the murder conviction, and remanded the case for a new trial on that charge. The court also addressed the admissibility of the defendant's use of homophobic slurs, ruling that the trial court did not abuse its discretion in admitting the entire interview, as it was relevant to the defendant's emotional state and the extreme emotional disturbance defense. View "State v. Parris" on Justia Law

The case involves a dispute between two competing slates of candidates, the Airey slate and the Green slate, who sought to appear on the ballot for the Democratic Town Committee primary election for Hartford's seventh district. Hartford election officials initially certified both slates for the primary. However, the Airey slate filed a complaint to disqualify the Green slate, and the Green slate counterclaimed to disqualify the Airey slate. The trial court ruled that only the Airey slate qualified, leading to the cancellation of the primary. On appeal, the higher court determined that neither slate qualified for the primary.The trial court, on remand, denied the Green slate's motion for a new primary election, reasoning that it lacked the authority to order a new primary under General Statutes § 9-329a (b) (3) because neither slate had qualified for the primary. The court noted that the statute contemplates a contested primary election that either was held or will be held, but in this case, no primary was held, and no candidates qualified.The Supreme Court of Connecticut affirmed the trial court's decision, holding that the trial court correctly concluded it lacked authority under § 9-329a (b) (3) to order a new primary. The court reasoned that the statute does not authorize a new primary when no candidates qualified for the original primary, and any vacancies should be filled according to local party rules. The court also rejected the Green slate's claim that the trial court's decision violated the fundamental rights of Democratic voters, as the candidates' failure to qualify for the primary was the cause of the canceled primary, not the court's decision. Lastly, the court declined to overrule or narrow the imputed knowledge doctrine, which grants standing to candidates aggrieved by election officials' decisions. View "Airey v. Feliciano" on Justia Law

The case involves a dispute between John B. Clinton, a former member and manager of CCP Equity Partners, LLC (CCP), and three other members and managers of CCP, Michael E. Aspinwall, Steven F. Piaker, and David W. Young. Clinton alleged that the defendants breached their contractual duties under CCP’s operating agreement by amending the agreement in 2008, removing him as a member in 2013, and maintaining an unnecessary $3 million capital reserve fund.The trial court, after a jury trial, found in favor of Clinton on his breach of contract claim, awarding him damages. The defendants appealed, arguing that the trial court incorrectly interpreted the second sentence of the duty of care provision in the operating agreement as imposing affirmative duties on them and improperly instructed the jury based on that interpretation. They also contended that the trial court abused its discretion by admitting the testimony of Clinton’s expert witness regarding the capital reserve fund.The Connecticut Supreme Court reviewed the case and agreed with the defendants that the trial court misinterpreted the second sentence of the duty of care provision, which is an exculpatory clause under Delaware law that limits liability rather than creating duties. The court found that the trial court’s jury instructions were incorrect and harmful, as they allowed the jury to find the defendants liable for acting in bad faith or with gross negligence or willful misconduct, which are not duties imposed by the agreement. The court also noted that the trial court improperly delegated the task of determining whether the contract provisions were ambiguous to the jury.The Connecticut Supreme Court reversed the trial court’s judgment and remanded the case for a new trial. The court also vacated the trial court’s awards of attorney’s fees, costs, and interest to Clinton. However, the court found no abuse of discretion in the trial court’s admission of the expert witness’s testimony regarding the capital reserve fund. View "Clinton v. Aspinwall" on Justia Law

The case involved a defendant who, along with an accomplice, planned and executed a robbery of a rideshare driver. The two men lured the victim under the pretense of hiring him for a ride, forced him to drive to a park, robbed him of his belongings, and then both shot him, resulting in the victim’s death. After the crime, the accomplice confided in his girlfriend and a close family friend, describing the events and implicating both himself and the defendant in the robbery and murder.The Superior Court in the judicial district of New Haven presided over the trial. The jury found the defendant guilty of felony murder, murder, robbery in the first degree, and conspiracy to commit robbery in the first degree. The court later vacated the felony murder conviction due to double jeopardy concerns. The court also found the defendant guilty of carrying a pistol without a permit and criminal possession of a firearm after a bench trial. The defendant was sentenced to eighty years of incarceration. Prior to trial, the court denied the defendant’s motion to suppress the accomplice’s statements, finding them admissible under the statement against penal interest exception to the hearsay rule.On appeal, the Supreme Court of Connecticut reviewed whether the trial court erred in admitting the accomplice’s statements to his girlfriend and family friend as evidence. The Supreme Court held that the trial court did not abuse its discretion in admitting these statements. The Court found that the statements were against the accomplice’s penal interest, made voluntarily and soon after the crime to trusted individuals, and were corroborated by other evidence. The Court also determined that any inconsistencies in the statements did not undermine their trustworthiness. The judgment of the trial court was affirmed. View "State v. Traynham" on Justia Law

A 93-year-old woman was found dead in her Stamford, Connecticut home in September 2019, having suffered multiple blunt force injuries. The back door was found open, her wallet was empty and bloodstained, her wedding rings were missing, and a hammer believed to be the murder weapon was found nearby. Video surveillance from a neighboring business showed only one person, later identified as the defendant, entering and exiting the victim’s home during the relevant time. Forensic evidence included the victim’s blood on the defendant’s jeans and the defendant’s DNA on the victim’s fingernails. The defendant initially denied knowing the victim or being in the area, but later admitted to visiting her home that day, claiming it was a brief, uneventful visit.The defendant was charged in the Superior Court for the judicial district of Stamford-Norwalk with murder, home invasion, felony murder, and burglary in the first degree. A jury convicted him on all counts, but the trial court vacated the felony murder conviction on double jeopardy grounds and rendered judgment on the remaining charges, sentencing him to eighty-five years in prison. The defendant appealed, arguing insufficient evidence, improper denial of a third-party culpability jury instruction, and prosecutorial impropriety during closing arguments.The Connecticut Supreme Court affirmed the conviction. It held that the evidence, including surveillance footage, forensic results, and the defendant’s contradictory statements, was sufficient for the jury to find guilt beyond a reasonable doubt. The court found no abuse of discretion in the trial court’s refusal to instruct the jury on third-party culpability, as the presence of unknown male DNA on the hammer did not, in context, provide a credible alternative theory of guilt. The court also concluded that the prosecutor’s remarks during argument were not improper and did not deprive the defendant of a fair trial. View "State v. Simmons" on Justia Law

The defendant was convicted of multiple crimes, including first-degree robbery, following an armed robbery at a restaurant. The police apprehended the defendant shortly after the robbery and conducted a one-on-one showup identification with a restaurant employee, Brinkley, who identified the defendant as one of the perpetrators. The defendant moved to suppress this identification, arguing it was unnecessarily suggestive and unreliable. The trial court denied the motion, finding the identification procedure was not unduly suggestive and, even if it was, the identification was reliable under the totality of the circumstances.The Appellate Court affirmed the trial court's decision, concluding that the showup identification was not unnecessarily suggestive due to the exigent circumstances of the investigation. The court noted that the police needed to quickly determine if they had apprehended the correct suspect to continue their investigation effectively and ensure public safety.The Supreme Court of Connecticut reviewed the case, assuming arguendo that the showup procedure was unnecessarily suggestive. The court focused on the reliability of the identification, considering factors such as Brinkley's opportunity to view the defendant during the crime, her degree of attention, the accuracy of her prior description, her level of certainty during the identification, and the short time between the crime and the identification. The court found substantial evidence supporting the trial court's finding of reliability, noting that Brinkley provided a detailed and accurate description of the perpetrators, identified the defendant without hesitation, and the identification occurred shortly after the crime.The court also addressed the defendant's arguments regarding estimator variables, such as the potential impact of Brinkley's fear, possible marijuana use, and the presence of a weapon. The court concluded that these factors did not undermine the reliability of the identification. Consequently, the Supreme Court of Connecticut affirmed the Appellate Court's judgment, holding that the identification was reliable and did not violate the defendant's due process rights. View "State v. McLaurin" on Justia Law

The defendant was convicted of murder and criminal possession of a firearm in connection with the shooting death of the victim. After the jury foreperson announced a guilty verdict and the jurors collectively confirmed it, defense counsel requested individual polling of the jurors. The first five jurors confirmed the verdict, but the sixth juror, S.C., expressed uncertainty and disagreement. The court stopped polling and excused the jurors to consult with counsel. The court then directed the jurors to resume deliberations, and they later returned a unanimous guilty verdict.In the trial court, the defendant moved for a mistrial, arguing that S.C. would face undue pressure in deliberations. The court denied the motion, noting that S.C. had expressed second thoughts and wanted to continue deliberating. The jury deliberated for an additional two hours after a lunch break and returned a unanimous guilty verdict, which was confirmed by all jurors during a second poll.The Supreme Court of Connecticut reviewed the case and held that the trial court did not abuse its discretion in denying the motion for a mistrial. The court found no impermissible coercion of S.C., noting that the trial court's actions were neutral and allowed the deliberation process to continue without undue pressure. The court also concluded that the trial court's instructions to the jury were adequate and did not require a Chip Smith charge. The court affirmed the judgment of conviction, rejecting the defendant's claims of coercion and procedural error. View "State v. Bolton" on Justia Law