Justia Connecticut Supreme Court Opinion Summaries

The Supreme Court answered a question certified to the Supreme Court by the United States District Court for the District of Connecticut in this declaratory judgment action by holding that Defendant's plea of nolo contendere could not be used to trigger a criminal acts exclusion in a homeowners insurance policy governed by Connecticut law.At issue was whether Plaintiff, Allstate Insurance Company, could use Defendant's plea of nolo contendere to the charge of assault in the first degree to trigger a criminal acts exclusion that would bar Plaintiff's coverage of Defendant in a civil action involving the same underlying incident. The district court certified the question to the Supreme Court. The Supreme Court answered that Defendant's plea of nolo contendere could not be used by Plaintiff to establish the applicability of the criminal acts exclusion of the relevant policy. View "Allstate Insurance Co. v. Tenn" on Justia Law

The Supreme Court affirmed the motion of the trial court denying the State's motion to dismiss this medical malpractice action on the basis of sovereign immunity, holding that the trial court did not err.James Caverly died while under the medical care of the employees of the John Dempsey Hospital at the University of Connecticut Health Center. Plaintiff, administrator of the decedent's estate, brought a medical malpractice action against the State, doing business as UCONN Health Center/John Dempsey Hospital, pursuant to Conn. Gen. Stat. 4-160(b). The State filed a motion to dismiss the action, arguing that because Plaintiff had received a settlement payment from a joint tortfeasor in connection with the decedent's death. The trial court denied the motion, concluding that section 4-160b(a) applies only to subrogated or assigned claims and not to payments made by joint tortfeasors. The Supreme Court affirmed, holding that the trial court properly denied the State's motion to dismiss. View "Caverly v. State" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of two counts of assault in the second degree, holding that the trial court did not commit reversible error.Specifically, the Supreme Court held (1) there was sufficient evidence to sustain the jury’s verdict of guilty of assault in the second degree; (2) the trial court did not err in denying Defendant’s request to cross-examine the victim more extensively regarding her pending civil action against Defendant arising out of the same incident; and (3) the trial court did not abuse its discretion in allowing a paramedic, testifying as a fact witness, to testify regarding symptoms of a concussion. View "State v. Fisher" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of murder and criminal possession of a pistol or revolver, holding that any error in the proceedings below was harmless.Specifically, the Supreme Court held (1) the trial court acted within its discretion in admitting testimony from four lay witnesses identifying Defendant in video surveillance footage; (2) the trial court properly admitted expert testimony regarding an enhancement of the video surveillance footage, and any error in the court's conclusion that defense counsel had opened the door to certain testimony elicited during the prosecutor’s redirect examination of the expert was harmless; (3) the trial court properly denied Defendant’s request for a special credibility instruction as to a witness whom Defendant claimed should have been treated as a jailhouse informant; (4) any error in the trial court's admission of identifications of Defendant made by Nigel Watts was harmless; and (5) there was sufficient evidence to support Defendant's conviction for criminal possession of a pistol or revolver. View "State v. Bruny" on Justia Law

The Supreme Court amended section 7-3(a) to the Connecticut Code of Evidence to incorporate an exception for testimony relating to the identification of persons depicted in surveillance video or photographs and affirmed the judgment of the trial court in this case, holding that the amendment did not affect the result in this appeal.After a jury trial, Defendant was found guilty of murder and criminal possession of a firearm. At issue on appeal was the wisdom of the "ultimate issue rule" as applied to lay witness identifications of persons depicted in video surveillance footage. The Supreme Court affirmed Defendant's convictions, holding (1) section 7-3(a) of the Connecticut Code of Evidence is hereby amended to incorporate an exception to the ultimate issue rule for lay opinion testimony that relates to the identification of persons depicted in surveillance video or photographs; (2) State v. Finan, 881 A.2d 187 (Conn. 2005), is hereby overruled; and (3) this Court adopts a totality of the circumstances test for determining whether lay opinion testimony identifying a person in surveillance video or photographs is admissible. View "State v. Gore" on Justia Law

The Supreme Court affirmed the judgment of the trial court dismissing Appellants' administrative appeal from a declaratory ruling of the Connecticut State Employees Retirement Commission, holding that the trial court properly upheld the Commission's interpretation of various provisions of the State Employees Retirement Act, Mass. Gen. Stat. 5-152 et seq.Plaintiffs, former state employees, argued that the Commission improperly issued a declaratory ruling that, under various provisions of the Act, disability retirement benefit payments commence on the first day of the month following the Retirement Services Division's receipt of the employee's approved application for such benefits. The Supreme Court affirmed the judgment of the trial court upholding the Commission's decision, holding (1) the trial court properly gave substantial deference to the Commission's position that disability retirement benefits become payable on the first day of the month after the application is received; and (2) Plaintiffs failed to prove their second claim. View "Crandle v. Connecticut State Employees Retirement Commission" on Justia Law

The Supreme Court affirmed the judgment of the appellate court reversing the judgment of the trial court and concluding that a genuine issue of material fact existed as to whether Plaintiff's action was barred by the two-year statute of limitations set forth in Conn. Gen. Stat. 52-584, holding that the appellate court did not err.Plaintiff fell while using a restroom in the Manchester Memorial Hospital and sustained injuries to her shoulder and neck. Plaintiff brought this action alleging that her fall resulted from Defendants' negligence in failing to exercise the care and diligence ordinarily exercised by hospitals. The trial court granted summary judgment for Defendants. The appellate court reversed, concluding that a genuine issue of material fact existed as to when Plaintiff discovered her injury as contemplated by section 52-584. The Supreme Court affirmed, holding that the appellate court correctly concluded that there was a genuine issue of material fact. View "Peek v. Manchester Memorial Hospital" on Justia Law

The Supreme Court reversed the judgment of the trial court dismissing the appeal of the decision of the Commission on Human Rights and Opportunities finding that Defendants - Edge Fitness and Club Fitness - did not engage in discriminatory public accommodations practices, holding that there is no implied gender privacy exception to Conn. Gen. Stat. 46a-64, the Public Accommodation Act.The trial court concluded that women's only workout areas in otherwise public gyms did not violate section 46a-64. The Supreme Court reversed, holding (1) the exceptions to the general prohibition against discrimination on the basis of sex in public accommodations are limited to those expressly provided by the plain language of section 46a-64; and (2) Defendants' gyms were places of public accommodation that denied the complainants full and equal accommodations on the basis of their sex. View "Commission on Human Rights & Opportunities v. Edge Fitness, LLC" on Justia Law

The Supreme Court held that a spouse seeking pendente lite alimony, attorney’s fees, and expert fees during the pendency of a dissolution action must demonstrate that a postnuptial agreement that purportedly precludes such payments is invalid or otherwise unenforceable before the trial court may properly order the other spouse to make such payments. After their marriage, Plaintiff and Defendant executed a postnuptial agreement setting forth terms for the distribution of property and determining support awards in the event their marriage dissolved. Plaintiff later brought this action seeking dissolution of the marriage and temporary and permanent alimony. The trial court ordered Defendant to pay Plaintiff temporary alimony, current attorney's fees and a retainer for legal counsel, and a contribution toward specified future expert fees. The Supreme Court affirmed, holding that the trial court correctly determined that it need not determine the enforceability of the parties' postnuptial agreement before awarding Plaintiff alimony and litigation expenses. View "O.A. v. J.A." on Justia Law

The Supreme Court reversed the judgment of the trial court denying Defendant's motion to correct an illegal sentence, holding that the trial court abused its discretion by denying Defendant's motion to correct.Defendant, a juvenile offender, was convicted of two counts each of kidnapping in the first degree and sexual assault in the first degree, among other offenses. The sentencing court imposed a total effective sentence of sixty years of incarceration. Relying on later changes to juvenile sentencing law, Defendant filed a motion to correct an illegal sentence. The trial court rejected Defendant's claims. The Supreme Court reversed, holding (1) the sentencing court substantially relied on a materially false and unreliable theory; and (2) therefore, Defendant's sentence was imposed in an illegal manner in violation of his right to due process, and the trial court erred in denying Defendant's motion to correct. View "State v. Belcher" on Justia Law