Justia Connecticut Supreme Court Opinion Summaries

The Supreme Court affirmed the decision of the trial court granting Defendant's motion to dismiss the information against him, holding that the trial court did not err in concluding that the statute of limitations was not tolled by Conn. Gen. Stat. 54-193(c).Defendant was charged with possession of child pornography in the first degree. Pursuant to a warrant, Defendant was arrested nearly five years after the warrant was issued and more than three years after the applicable statute of limitations had expired. The trial court granted Defendant's motion to dismiss, concluding (1) the tolling provision of section 54-193(c) was inapplicable once the warrant was issued within the limitation period, and (2) the almost five-year delay in executing the warrant was unreasonable under State v. Crawford, 521 A.2d 1034 (Conn. 1987). The Supreme Court affirmed, holding that although section 54-193 (c) tolls the limitation period within which a prosecution may be commenced, Crawford and its progeny establish that, once an arrest warrant has been issued, the State must serve the warrant without undue delay. View "State v. A.B." on Justia Law

The Supreme Court reversed in part the judgment of the appellate court reversing in part the judgment of the trial court in favor of Plaintiffs, the town of South Windsor and its zoning enforcement officer and remanding the case for a new trial on count two of the complaint, holding that the appellate court improperly remanded the case.The trial court assessed a fine and imposed injunctive relief for certain zoning violations pursuant to Conn. Gen. Stat. 8-12. The appellate court remanded the case for a new trial, concluding that the trial court had improperly assessed a fine on Defendant for zoning violations for a period of time that she was under lawful orders not to disturb her property because of an ongoing fire investigation. The Supreme Court reversed, holding that no dispute remained as to Defendant's liability for the zoning violations alleged in count two of Plaintiffs' complaint. View "Town of South Windsor v. Lanata" on Justia Law

The Supreme Court affirmed the judgment of the appellate court affirming the trial court's dismissal of the statutory theft claim Plaintiff brought against Defendant for lack of subject matter jurisdiction on the ground of absolute immunity, holding that there was no error.Defendant, an attorney, represented Benchmark Municipal Tax Services, Ltd., in the foreclosure proceeding underlying this appeal. The appellate court determined that Defendant was entitled to absolute immunity from Plaintiff's claim of statutory theft by concluding that public policy considerations were served by granting Defendant this immunity and that the entirety of Defendant's alleged misconduct occurred within the scope of the foreclosure proceeding. The Supreme Court affirmed, holding that Plaintiff's arguments on appeal failed. View "Scholz v. Epstein" on Justia Law

The Supreme Court reversed the judgment of the trial court convicting Defendant of four counts of patronizing a prostitute and one count of trafficking in persons as an accessory, holding that the state presented insufficient evidence to convict Defendant of any of the charged counts.On appeal, Defendant claimed, among other things, that the state presented insufficient evidence for a reasonable jury to have concluded that he knew or reasonably should have known that the men with whom he engaged in sexual conduct for a fee were victims of trafficking. The Supreme Court reversed, holding (1) there was insufficient evidence to convict Defendant of the crime of patronizing a prostitution; and (2) the evidence was insufficient to prove Defendant was guilty of the crime of trafficking in persons as an accessory because the state did not prove that he had the specific intent necessary for accessorial liability for the crime of trafficking in persons. View "State v. Bemer" on Justia Law

The Supreme Court affirmed the judgment of the trial court dismissing Plaintiff's administrative appeal from the decision of the Connecticut Siting Council approving the application of NTE Connecticut, LLC (NTE) seeking a certificate of environmental compatibility and public need for the construction of an electric generating facility in the town of Killingly, holding that there was no error.Plaintiff, a nonprofit organization, appealed the council's decision to the trial court, arguing that the council improperly refused to consider the environmental impact of installing a gas pipeline to its proposed facility when weighing the public benefit of the facility against its probable environmental impact. The trial court dismissed the appeal, concluding that the council was not required to consider the impact of the gas pipeline. The Supreme Court affirmed, holding that the trial court correctly determined that the council’s refusal to consider the potential environmental impact of the gas pipeline during the proceedings on NTE’s application for a certificate was not arbitrary or capricious. View "Not Another Power Plant v. Connecticut Siting Council" on Justia Law

The Supreme Court affirmed Defendant's conviction of two counts of murder, holding that Defendant was entitled to relief on her argument that no rational finder of fact reasonably could have rejected her insanity defense on the present factual records.Specifically, the Supreme Court held that the trier of fact reasonably credited the State's expert testimony presented to rebut Defendant's insanity defense that, at the time Defendant murdered her two children, she was not suffering from a mental disease or defect, was able to appreciate the wrongfulness of her conduct, and was able to conform her conduct to the requirements of law. View "State v. LeRoya M." on Justia Law

The Supreme Court affirmed the judgment of the trial court seeking to enforce a California judgment or, alternatively, to recover under the theories of breach of contract or quantum meruit, holding that the trial court did not err in rendering judgment in favor of Plaintiff.This case arose out of a dispute arising in connection a contract for the design, decoration, and staging for sale of Defendants' home. Plaintiff, a California company, obtained a default judgment against Defendants and thereafter filed an action in the superior court seeking to enforce the California judgment or to recover under the theories of breach of contract or quantum meruit. The trial court rendered judgment for Plaintiff on the count seeking to enforce the California judgment and in favor of Plaintiff on the breach of contract count. The Supreme Court affirmed, holding (1) the trial court correctly enforced the California judgment against Defendant; (2) the trial court correctly determined that the agreement was not subject to the notice of cancellation provisions in the Home Solicitation Sales Act, Conn. Gen. Stat. 42-134a et seq., (3) the damages award was proper. View "Meribear Productions, Inc. v. Frank" on Justia Law

The Supreme Court reversed the judgment of the appellate court affirming Defendant's conviction, holding that the warrantless canine sniff conducted by law enforcement officers of the exterior door to a motel room for the purpose of detecting the presence of illegal drugs inside the room violated the warrant requirement of Conn. Const. Art. I, 7.After Defendant was charged with several drug-related offenses he filed a motion to suppress the evidence that had been seized from his motel room pursuant to a search warrant. The trial court denied the motion. Thereafter, Defendant entered a conditional plea of solo contenders. The appellate court affirmed. The Supreme Court reversed, holding that the appellate court erred in concluding (1) the canine sniff was not a search that violated Defendant's rights under article 1, section 7; and (2) the visual sweep of Defendant's motel room was justified by the exigencies of the situation. The Court remanded the case for further proceedings. View "State v. Correa" on Justia Law

The Supreme Court affirmed Defendant's conviction of murder and carrying a pistol without a permit, holding that while evidence regarding a defendant's gang affiliation may prejudice a jury against a defendant, there was no prejudicial error in this case.On appeal, Defendant argued that the trial court erred in admitting certain evidence, including police photographs arguably reflecting Defendant's gang membership. The Supreme Court affirmed, holding (1) any error in the trial court's admission of expert testimony regarding local street gangs was harmless beyond a reasonable doubt; (2) the trial court did not abuse its discretion in admitting the photographs at issue; and (3) Defendant's remaining evidentiary arguments were unavailing. View "State v. Tomlinson" on Justia Law

The Supreme Court affirmed the judgment of the trial court determining that property used for a residential mental health treatment program was tax exempt under Conn. Gen. Stat. 12-81(7), holding that the court did not err.The trial court granted the exemption on the residential mental health treatment program on the grounds that it did not provide housing subsidized by the government and that any housing provided was temporary. The Supreme Court affirmed, holding (1) Defendant failed to establish that the trial court lacked subject matter jurisdiction; (2) the trial court properly found that the program's housing was temporary and therefore qualified for the exemption on that basis; and (3) therefore, the trial court correctly rendered summary judgment in favor of Plaintiffs. View "Rainbow Housing Corp. v. Cromwell" on Justia Law