Justia Connecticut Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the trial court convicting Defendant of one count of sexual assault in the first degree and two counts of risk of injury to a child, holding that Defendant was not entitled to relief on his claims of error.On appeal, Defendant argued that the State infringed on his right to due process by providing an inadequate notice of intent to offer evidence of other sexual misconduct and that the trial court abused its discretion by admitting the testimony of his daughter concerning sexual misconduct he had engaged in with her fourteen years earlier. The Supreme Court affirmed, holding (1) Defendant had no constitutional right to pretrial notice of other sexual misconduct evidence; and (2) the trial court did not abuse its discretion by admitting evidence of Defendant's other sexual misconduct with his daughter. View "State v. Samuel U." on Justia Law

The Supreme Court reversed the judgment of the trial court in favor of Defendant Barbara Lembo in this action brought by beneficiaries of an inter vivos trust and their mother alleging that Defendant breached her fiduciary duty as trustee, holding that the allegations in the complaint stated a legally sufficient claim for breach of a trustee's fiduciary duties under Connecticut law.The will of the decedent bequeathed the residue of his estate to an amended and restated revocable trust benefitting his three children. At issue was the proper administration of a portion of the decedent's residuary estate that had not yet been distributed to the trust. Plaintiffs brought this action alleging that Defendant, among other things, breached her fiduciary duty by failing to protect and collect trust property. The trial court concluded that Defendant, as a trustee, had no duty to take any action prior to the distribution of the residuary assets. The Supreme Court reversed, holding (1) a genuine issue of material fact remained as to whether Defendant owed the trust beneficiaries a duty to collect and protect the prospective trust property in the residuary estate; and (2) the complaint sufficiently alleged a cause of action against Defendant for breach of her fiduciary duty as trustee. View "Barash v. Lembo" on Justia Law

The Supreme Court affirmed the judgment of the appellate court determining that the State Board of Labor Relations did not act unreasonably, illegally, arbitrarily, or in abuse of its discretion when it applied the clear and unmistakable waiver standard to a union's claim that the town's unilateral change to its pension plan constituted a refusal to bargain collectively in good faith, holding that there was no error.The Town of Middlebury appealed the labor board's determination that the Town violated the Municipal Employee Relations act (MERA), Mass. Gen. Stat. 7-467 et seq., by unilaterally changing the Town's practice of including extra pay duty in calculating pension benefits for members of the Fraternal Order of Police, Middlebury Lodge No. 34. The appellate court concluded that the labor board did not abuse its discretion or act unreasonably, illegally, or arbitrarily when it declined to apply the "contract coverage" standard adopted by the National Labor Relations Board (NLRB) in 2019. The Supreme Court affirmed, holding that it was proper for the appellate court to apply the clear and unmistakable waiver standard, rather than the contract coverage standard, in determining when whether the union had waived its statutory right to bargain collective regarding the manner in which the Town calculated its members' pension benefits. View "Middlebury v. Fraternal Order of Police, Middlebury Lodge No. 34" on Justia Law

The Supreme Court affirmed the judgment of the trial court denying Plaintiff's application to vacate an arbitration award rendered in favor of Defendant and granting Defendant's motion to confirm the award, holding that Plaintiff failed to satisfy any of the legal standards required for reversal of the trial court's judgment.Defendant filed an arbitration complaint asserting claims of breach of contact, breach of fiduciary duty, and common-law fraud. The arbitrator issued an award in favor of Defendant. Thereafter, Plaintiff filed an application to vacate the award. The trial court denied the application to vacate and granted Defendant's motion to confirm the award. The Supreme Court affirmed, holding (1) the arbitrator gave Plaintiff the full and fair hearing to which he was entitled under governing law, public policy, and the parties' arbitration agreement; and (2) the arbitrator properly applied the fugitive disentitlement doctrine to prevent Plaintiff from asserting counterclaims or defenses, contesting the allegations, and viewing the evidence against him. View "Ahmed v. Oak Management Corp." on Justia Law

The Supreme Court affirmed the judgment of the trial court awarding damages to Companions and Homemakers, Inc. for tortious interference with contractual and business relations and a violation of the Connecticut Unfair Trade Practices Act (CUTPA), Conn. Gen. Stat. 42-110a et seq., holding that A&B Homecare Solutions, LLC was not entitled to relief on its allegations of error.Companions, the largest provide of Medicaid and state-funded home care services in Connecticut, brought this action against A&B. Following a jury trial, the trial court rendered judgment for Companions. The Supreme Court affirmed, holding (1) the trial court did not err in finding that A&B's misrepresentations were tortious; (2) the evidence was sufficient to establish that A&B's allegedly tortious interference cause Companions to suffer damages; and (3) the trial court did not err in finding that A&B's conduct was a violation of CUTPA. View "Companions & Homemakers, Inc. v. A&B Homecare Solutions" on Justia Law

The Supreme Court affirmed the judgment of the appellate court concluding that enforcement of in terrorem, or no-contest, clauses in the decedent's will and trust agreement against Defendant would violate public policy, holding that the appellate court did not err.Plaintiff was the son and Defendant was the daughter of Mae Salce, the settlor of the trust agreement in this case. Both the trust agreement and the will contained an in terrorem clause providing that if a beneficiary takes certain actions she forfeits her rights as a beneficiary under the instruments. The appellate court concluded that enforcement of the clauses against Defendant, a beneficiary, would violate public policy when Defendant challenged certain aspects of the performance of a fiduciary. The Supreme Court affirmed, holding that because Defendant's actions were based in good faith, enforcement of the in terrorem clauses would violate the public policy embodied in statutes requiring probate courts to supervise fiduciaries. View "Salce v. Cardello" on Justia Law

The Supreme Court affirmed the judgment of the appellate court concluding that the trial court lost jurisdiction when it dismissed Defendant's pending criminal charges and, therefore, was without jurisdiction to entertain the State's motion to open the judgment and reinstate the charges, holding that criminal courts do not have jurisdiction to open a judgment following a dismissal.After Defendant was charged with risk of injury to a child and breach of the peace in the second degree the court granted his application to participate in a supervised diversionary program for individuals with psychiatric disabilities. The trial court later dismissed the charges against him. The State moved to open the judgment of dismissal on the grounds that Defendant failed to satisfactorily complete the diversionary program. The trial court granted the motion on the grounds that the dismissal was erroneous. The appellate court reversed, concluding that the trial court lost jurisdiction over the matter when it rendered the judgment of dismissal. The Supreme Court affirmed, holding that the appellate court properly concluded that the trial court lacked jurisdiction to entertain the State's motion to open the judgment and reinstate the charges. View "State v. Butler" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the trial court finding Defendant guilty of manslaughter in the first degree, criminal possession of a firearm, and possession of a weapon in a motor vehicle, holding that the evidence was insufficient to support Defendant's conviction of possessing a weapon in a motor vehicle.Specifically, the Supreme Court held (1) any claimed error on the part of the trial court in violating Defendant's right to confront the witnesses against him under the Sixth Amendment by allowing the chief medical examiner to testify about the results of the victim's autopsy, which the chief medical examiner had not performed himself, was harmless; and (2) the evidence was insufficient to support Defendant's conviction of possessing a weapon in a vehicle in violation of Conn. Gen. Stat. 29-38(a). View "State v. Robles" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of one count of sexual assault in the first degree and two counts of risk of injury to a child, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Court held (1) the trial court did not err in admitting certain testimony pursuant to the constancy of accusation doctrine; (2) the trial court did not err in excluding impeachment evidence of pending criminal charges against the State's key witness; and (3) the first degree of sexual assault charge was not ambiguous and therefore did not violate Defendant's right to jury unanimity under the Sixth Amendment. View "State v. Velasquez-Mattos" on Justia Law

The Supreme Court affirmed the judgment of the trial court dissolving Plaintiff's marriage to Defendant, holding that Plaintiff was not entitled to relief on his allegations of error.At issue in this case was the extent to which a Connecticut court may enforce the terms of a "ketubah," a contract governing marriage under Jewish law. The trial court in this case denied Plaintiff's motion to enforce the terms of the parties' ketubah as a prenuptial agreement on the ground that doing so would be a violation of the First Amendment to the United States constitution. The Supreme Court affirmed, holding (1) the trial court properly denied Plaintiff's motion to enforce the ketubah; and (2) the trial court's alimony order, considered in light of Plaintiff's net earning capacity, was not an abuse of discretion. View "Tilsen v. Benson" on Justia Law