Justia Connecticut Supreme Court Opinion Summaries

The defendant was charged with multiple offenses related to a series of robberies and burglaries in 2020. He was incarcerated following his arrest in October 2020. During pretrial proceedings, the defendant reached a plea agreement with the state, which included a total effective sentence of ten years of imprisonment followed by five years of special parole. The sentences were to run concurrently and be stayed until April 1, 2022, to ensure that the defendant's pretrial credit was not affected.The defendant pleaded guilty in multiple judicial districts, and the courts issued sentences in accordance with the plea agreement. However, the defendant later filed a motion to correct an illegal sentence, arguing that he was promised 521 days of presentence confinement credit, but the commissioner of correction applied fewer days, resulting in a longer effective sentence.The trial court in the judicial district of New Britain dismissed the defendant's motion for lack of subject matter jurisdiction, citing the Appellate Court's decision in State v. Hurdle, which held that trial courts lacked authority under General Statutes § 18-98d to award presentence confinement credit.The Supreme Court of Connecticut reviewed the case and concluded that trial courts do have the authority to direct the commissioner to apply specific presentence confinement credit to a sentence on a judgment mittimus, as established in the companion case of State v. Hurdle. The court also determined that the defendant's motion raised a colorable claim that the plea agreement required the application of 521 days of presentence confinement credit and that there was no indication the defendant waived his statutory right to this credit.The Supreme Court of Connecticut reversed the trial court's judgment and remanded the case for further proceedings to consider the merits of the defendant's motion to correct an illegal sentence. View "State v. Nixon" on Justia Law

The defendant was charged with violating a protective order and was sentenced to five years of incarceration, execution suspended, followed by five years of probation. Later, he was arrested for threatening and subsequently charged with violating his probation. Due to COVID-19 related delays, the violation of probation arrest warrant was not served until several months after it was issued. The defendant remained in custody for several months before being released on bond. The trial court found the defendant in violation of his probation, revoked his probation, and sentenced him to five years of incarceration, execution suspended after six months, followed by three years and 250 days of probation.The trial court declined the defendant's request to direct the commissioner of correction to apply specific presentence confinement credit to his sentence, stating that the determination of such credits was within the purview of the Department of Correction. The defendant appealed this decision to the Appellate Court, which affirmed the trial court's judgment, relying on its decision in State v. Hurdle, which held that trial courts lack authority to award presentence confinement credit under General Statutes § 18-98d.The Supreme Court of Connecticut reviewed the case and concluded that trial courts do have the authority to direct the commissioner to apply specific presentence confinement credit to a sentence on a judgment mittimus, as established in the companion case of State v. Hurdle. The court disagreed with the state's argument that the defendant was not entitled to credit starting from the date the arrest warrant was signed, noting that the defendant was not serving another sentence during that time. The Supreme Court reversed the Appellate Court's judgment in part and remanded the case to the trial court to exercise its discretion in accordance with this opinion. View "State v. Eric L." on Justia Law

The defendant was convicted of robbery in the first degree and conspiracy to commit robbery in the first degree following a guilty plea. He appealed, claiming that the trial court incorrectly concluded it lacked authority to direct the commissioner of correction to apply presentence confinement credit to his sentence. The defendant also argued that his plea agreement included an understanding that he would receive such credit and that there was no meeting of the minds on this issue, rendering the plea agreement void.The trial court had denied the defendant’s request for presentence confinement credit, stating it had no discretion under the statute to grant it. The court also denied the defendant’s motion to withdraw his guilty pleas, finding no reason to believe he did not understand the terms of the plea agreement. The Appellate Court affirmed the trial court’s judgment, concluding that the trial court lacked authority to award presentence confinement credit and that the plea agreement did not include an agreement for such credit.The Supreme Court of Connecticut reviewed the case and concluded that the trial court does have discretionary authority under the statute to direct the commissioner to apply specific presentence confinement dates to a sentence. The court found that the legislative history and statutory text support the trial court’s inherent authority to issue such orders. The court reversed the Appellate Court’s judgment regarding the trial court’s authority to order presentence confinement credit and remanded the case for the trial court to exercise its discretion on this issue.The Supreme Court also agreed with the Appellate Court that the plea agreement did not include an agreement for presentence confinement credit and that the defendant’s subjective belief that he would receive such credit was unreasonable. The court affirmed the Appellate Court’s judgment in all other respects. View "State v. Hurdle" on Justia Law

The case involves the dissolution of a marriage between the plaintiff, K, and the defendant, R, with the intervenor, B, also involved due to a related New Jersey litigation. The key marital asset was the couple's home in Greenwich, Connecticut, valued at approximately $11 million, and several investment accounts. The defendant had previously pledged these assets as security in a New Jersey court case, which resulted in a $24.7 million judgment against him and his father. The New Jersey court ordered the forfeiture of the Greenwich property and imposed a constructive trust on the investment accounts due to the defendant's misconduct, including transferring $3 million to Slovakia.The Connecticut trial court found that the defendant had dissipated marital assets by pledging and forfeiting the Greenwich property and investment accounts. The court included these assets in the marital estate and ordered their sale, with proceeds to be divided among the plaintiff, the defendant, and the intervenor. The court also found the defendant's annual earning capacity to be $400,000 and ordered him to pay $749 per week in child support, based on his earning capacity rather than actual income. Additionally, the court allowed the plaintiff to relocate with the children to the Czech Republic and granted her motion for contempt against the defendant for failing to support the family during the pendency of the dissolution action.The Connecticut Supreme Court reviewed the case and concluded that the trial court erred in failing to afford full faith and credit to the New Jersey court orders, which had removed the Greenwich property and investment accounts from the marital estate. The Supreme Court also found that the trial court improperly calculated child support by not first determining the presumptive amount based on the defendant's actual income. The court's granting of the plaintiff's motion for contempt was reversed due to a lack of clear and unambiguous orders requiring the defendant to provide the support he allegedly withheld. The case was remanded for a new hearing on all financial issues, including the division of the marital assets, giving full faith and credit to the New Jersey court orders. View "K. S. v. R. S." on Justia Law

The plaintiff, an electric distribution company, appealed from the trial court's dismissal of its consolidated administrative appeals from two final decisions by the Public Utilities Regulatory Authority (PURA). PURA had found the plaintiff violated statutory obligations related to emergency planning and storm recovery during an August 2020 tropical storm, intending to reduce the plaintiff's authorized return on equity (ROE) by fifteen basis points. Additionally, PURA imposed over $1.2 million in fines for violating storm performance standards and $61,000 in civil penalties for late reporting of minor accidents.The trial court dismissed the plaintiff's appeals, upholding PURA's decisions. The plaintiff then appealed to the higher court, challenging the ROE reduction, the fines for storm performance violations, and the penalties for late accident reporting. During the appeal, PURA decided not to implement the ROE reduction, rendering the issue moot. The court determined that neither the voluntary cessation nor the collateral consequences exceptions to the mootness doctrine applied. The court directed the vacatur of the portion of PURA's order authorizing the ROE reduction and the corresponding part of the trial court's judgment.Regarding the fines for late reporting of minor accidents, the court concluded that the failure to report a minor accident did not qualify as a "continued violation" under the statute. Instead, each monthly failure to report constituted a single, distinct violation. The case was remanded to the trial court to order PURA to recalculate the penalties accordingly.The court found sufficient evidence to support PURA's findings that the plaintiff violated storm performance standards by failing to provide a dedicated make safe crew for Bridgeport and inadequately communicating with city officials. The court affirmed the trial court's judgments in all other respects. View "United Illuminating Co. v. Public Utilities Regulatory Authority" on Justia Law

Three registered electors from Bridgeport filed a writ of error challenging a trial judge's decision to deny their applications for arrest warrants for two individuals who allegedly violated election laws during the 2023 Democratic primary for the mayoral office. The plaintiffs claimed that the trial judge misinterpreted the relevant statute, General Statutes § 9-368, which they argued mandated the issuance of arrest warrants upon their complaint. The state of Connecticut, the defendant in error, argued that the writ should be dismissed because the plaintiffs were neither statutorily nor classically aggrieved by the denial of their applications.The Superior Court for the judicial district of Fairfield, with Judge Thomas J. Welch presiding, denied the applications for arrest warrants. The judge concluded that § 9-368 was inconsistent with the federal and state constitutions and the rules of practice, as it allowed for the issuance of arrest warrants based on a standard less than probable cause and without coordination with the Division of Criminal Justice. The judge did not reach the substantive merits of the applications and suggested that the matter could be referred to a prosecuting authority.The Supreme Court of Connecticut reviewed the case. The court held that the plaintiffs in error were not required to establish statutory aggrievement to bring a writ of error. However, the court dismissed the writ on the grounds that the plaintiffs were not classically aggrieved. The court determined that the plaintiffs lacked a specific, personal, and legal interest in the arrest and prosecution of those who allegedly violated election laws, as they were private citizens without a judicially cognizable interest in the prosecution or nonprosecution of another. Consequently, the plaintiffs did not have standing to challenge the trial judge's denial of their arrest warrant applications. View "In re Criminal Complaint & Application for Arrest Warrant" on Justia Law

The plaintiff, a self-represented pediatric dentist, sued the defendant newspaper for defamation, alleging that two articles published by the defendant exaggerated the scope and seriousness of disciplinary proceedings against him. The articles reported on disciplinary actions taken by the Department of Public Health and the Connecticut State Dental Commission, which resulted in a reprimand, fines, and probation of the plaintiff’s dental license. The plaintiff claimed that five statements in the articles were defamatory and that a stock photograph accompanying the articles was independently defamatory.The trial court granted summary judgment in favor of the defendant, concluding that the five statements were either substantially true or protected by the fair report privilege under the First Amendment. The court did not address the photograph as an independent defamation claim, as the plaintiff had not distinctly raised it as such in his pleadings. The plaintiff appealed, and the Appellate Court affirmed the trial court’s judgment, declining to consider the photograph claim because it was not distinctly raised before the trial court.The Connecticut Supreme Court reviewed the case and affirmed the Appellate Court’s decision. The court held that the trial court did not err in granting summary judgment without treating the plaintiff’s references to the photograph as an independent defamation claim. The court emphasized that the plaintiff’s self-represented status did not relieve him of the obligation to sufficiently articulate his claims. The court also clarified that the fair report privilege is not defeated by demonstrating malice in fact, and that the privilege applies as long as the report is a fair and substantially accurate account of the proceedings. View "Idlibi v. Hartford Courant Co." on Justia Law

The case involves a billing dispute between a group of emergency room physicians (plaintiff) and an insurance company (defendant). The dispute centers on the interpretation of Connecticut’s surprise billing law, which aims to protect insured individuals from high medical bills when they receive emergency care from out-of-network providers. The plaintiff contends that the law requires the defendant to fully reimburse them for emergency services and then collect any applicable cost-sharing amounts (deductibles, copayments) from the insured. The defendant argues that it can deduct the insured’s cost-sharing amounts from the reimbursement it pays to the plaintiff.The United States District Court for the District of Connecticut dismissed the plaintiff’s stand-alone claims under the surprise billing law, concluding that the law does not create a private right of action. The court then certified three questions to the Connecticut Supreme Court: (1) whether a CUTPA claim can be maintained for conduct that violates the surprise billing law but not CUIPA, (2) whether the surprise billing law requires insurers to fully reimburse providers and then collect cost-sharing amounts from insureds, and (3) whether the defendant’s practice of deducting cost-sharing amounts from reimbursements violates the surprise billing law.The Connecticut Supreme Court held that Connecticut law does not recognize a cause of action under CUTPA for conduct that violates the surprise billing law but is not identified as an unfair insurance practice under CUIPA. The court also held that the surprise billing law does not require insurers to fully reimburse providers and then collect cost-sharing amounts from insureds. Instead, insurers can deduct the insured’s cost-sharing amounts from the reimbursement paid to the provider. Finally, the court concluded that the defendant’s practice of deducting cost-sharing amounts from reimbursements does not violate the surprise billing law. View "NEMS, PLLC v. Harvard Pilgrim Health Care of Connecticut, Inc." on Justia Law

The defendant was convicted of murder, criminal possession of a pistol or revolver, and carrying a pistol or revolver without a permit. The case involved the shooting death of the victim, Eric Diaz, who was selling drugs when he was approached by a man, later identified as the defendant, and a fight ensued in a black car, resulting in the victim being shot in the abdomen. The victim died from the gunshot wound. The police identified the car as a Nissan Maxima with a broken rear vent window, registered to Frank Bridgeforth but driven by the defendant. Forensic evidence and eyewitness testimonies linked the defendant to the crime.The trial court asked questions to three witnesses, including a police officer and two defense experts, which the defendant claimed were biased and prejudicial. The trial court’s questions aimed to clarify the preparation of a photographic array and the presence of gunshot residue in the car. The defendant did not object to these questions during the trial. The jury was instructed that the court’s questions should not influence their judgment.The Connecticut Supreme Court reviewed the case and found that the trial court’s questioning did not violate the defendant’s due process rights. The court held that the questions were not extensive or adverse enough to impair the jury’s function or the judge’s impartiality. The court also found sufficient evidence to support the defendant’s intent to kill, given the close-range shooting in a vital area and the defendant’s flight from the scene.The defendant’s claims of improper jury instructions were deemed waived because defense counsel had a meaningful opportunity to review and did not object to the instructions. The court concluded that the instructions, when viewed as a whole, were not clearly erroneous and did not constitute plain error. The judgment was affirmed. View "State v. Mebane" on Justia Law

The plaintiff sought damages from the defendant for negligence related to a motor vehicle accident. The original action was dismissed due to insufficient service of process, as the defendant had moved from the address where service was attempted. The plaintiff then filed a new action under the accidental failure of suit statute, § 52-592.The trial court granted the defendant's motion for summary judgment, concluding that the original action was not commenced within the time limited by law because the defendant did not receive the summons and complaint within the statutory period. The Appellate Court affirmed, agreeing that the defendant did not have actual or effective notice of the original action within the required time frame.The Supreme Court of Connecticut reviewed the case and affirmed the Appellate Court's decision. The court held that for an action to be "commenced" under § 52-592, the defendant must receive the summons and complaint within the time permitted by law, even if the service was improper. The court found that the plaintiff failed to establish that the defendant or her agent received the summons and complaint within the statutory period. Therefore, the original action was not commenced within the meaning of § 52-592, and the plaintiff could not rely on the savings statute to file a new action. View "Laiuppa v. Moritz" on Justia Law