Justia Connecticut Supreme Court Opinion Summaries

The Supreme Court reversed the judgment of the appellate court affirming Defendant's conviction of assault of a disabled person in the second degree, holding that Conn. Gen. Stat. 53a-60b(a)(1) and Conn. Gen. Stat. 1-1f(b) are unconstitutionally over inclusive and lack any rational basis as applied to assaults on persons whose physical disabilities neither diminish their ability to defend themselves from assault nor make them particularly vulnerable to injury.Defendant's conviction stemmed from an altercation with her sister, who suffered from fibromyalgia and other physical ailments, with a wooden billy club. On appeal from her conviction, Defendant argued that the statutes were unconstitutional vague as applied to her conduct and that the evidence did not support a finding that the victim was disabled. The appellate court affirmed. The Supreme Court reversed and remanded the case for a new trial, holding (1) sections 53a-60b(a)(1) and 1-1f(b) are not unconstitutionally vague; but (2) section 53a-60b(a)(1) is unconstitutionally overinclusive. View "State v. Jodi D." on Justia Law

The Supreme Court reversed the decision of the appellate court reversing the judgment of the trial court denying Defendant's motion to correct an illegal sentence on the basis of its conclusion that Defendant's convictions of manslaughter in the first degree and risk of injury to a child violate the constitutional prohibition against double jeopardy, holding that the appellate court erred.At issue on appeal was to what extent a court should consider the facts alleged in the charging documents when determining whether a crime is a lesser included offense of another rather than confining its analysis to the elements of the statutes at issue under Blockburger v. United States, 284 U.S. 299 (1932). The Supreme Court held that, insofar as risk of injury to a child is not a lesser included offense of manslaughter in the first degree, the appellate court improperly considered the facts alleged by the state in the information rather than confining its analysis under the Blockburger test. View "State v. Tinsley" on Justia Law

The Supreme Court affirmed the judgment of the appellate court concluding that the trial court's instructions in this criminal case, while improper, did not impact Defendant's due process right to a fair trial, holding that the appellate court did not err.Defendant was convicted of three counts of robbery in the first degree, two counts of felony murder, and other offenses for her involvement in two murders. The appellate court affirmed, holding that the trial court's instructions on robbery and felony murder were improper but provided the jury with a legally valid but factually unsupported basis for finding Defendant guilty. The Supreme Court affirmed, holding (1) the trial court's instructions provided the jury with a legally valid and factually supported alternative basis for finding Defendant guilty of robbery and felony murder; and (2) therefore, Defendant could not establish that the trial court's error more probably than not affected the jury's verdict. View "State v. Turner" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of felony murder, robbery in the first degree, conspiracy to commit robbery in the first degree, and criminal possession of a firearm, holding that Defendant's claims on appeal were unavailing.On appeal, Defendant argued that the trial court improperly admitted portions of a written statement from one of the state's witnesses and unduly restricted the cross-examination of another state witness. The Supreme Court affirmed, holding (1) Defendant failed to demonstrate that the admission of the witness's written statement substantially swayed the jury's verdict; and (2) assuming that partial restrictions placed on defense counsel's cross-examination of the second witness infringed on the minimum of cross-examination guaranteed by the Confrontation Clause of the Sixth Amendment, such infringement was harmless beyond a reasonable doubt. View "State v. Gibson" on Justia Law

The Supreme Court affirmed the judgment of the trial court dismissing for lack of personal jurisdiction this complaint against Defendants, Board and More GmbH (B&M) and Emeram Capital Partners GmbH (Emeram), holding that Plaintiff, North Sales Group, LLC, failed to demonstrate that Defendants had sufficient minimum contacts with Connecticut.B&M was a limited liability company chartered under the laws of Austria, with its principal place of business in Austria. Emeram was a private equity investment limited liability company, with its principal place of business in Germany. Neither company had maintained an agent for service of process in Connecticut, nor did the companies maintain offices or transact business in Connecticut. At issue on appeal was whether Plaintiff advanced sufficient allegations and evidence to establish minimum contacts with Defendants. The Supreme Court held that Plaintiff did not and that the trial court correctly dismissed the case for lack of personal jurisdiction. View "North Sails Group, LLC v. Boards & More GmbH" on Justia Law

The Supreme Court reversed in part the judgment of the appellate court reversing in part the trial court's judgment granting injunctive relief against Defendant and enforcing several restrictions against the property at issue in this case, holding that the appellate court incorrectly concluded that Plaintiffs lacked standing to enforce the residential use restriction.The trial court granted injunctive relief against Defendant that (1) enforced one restrictive covenant limiting the use of the subject property to residential use, which was contained in a deed that had been executed by the original grantors of the parties' real properties; and (2) enforced two other use restrictions that appeared in a separate declaration that applied to the properties. The appellate court reversed in part the lower court's judgment, concluding that Plaintiffs lacked standing to enforce the restrictive covenant in the deed that limited the use of Defendant's property to residential purposes. The Supreme Court reversed, holding that Plaintiffs had standing to enforce the restrictive covenant limiting the use of the properties to residential purposes only. View "Abel v. Johnson" on Justia Law

The Supreme Court affirmed the judgment of the trial court determining that Defendant, a municipal corporation that provided water to towns and boroughs in southeastern Connecticut, was not liable for the losses of Plaintiff, a hotel owner, when an explosion at Defendant's pumping station caused an interruption in the hotel's water service, holding that there was no error.On appeal, Plaintiff argued that the trial court erred in determining that Defendant could not be held liable for Plaintiff's losses because public policy did not support the imposition of a duty on Defendant under the circumstances of this case. The Supreme Court disagreed and affirmed, holding that the trial court properly determined that public policy did not support the imposition of a duty on Defendant under the facts and circumstances of this case. View "Raspberry Junction Holding, LLC v. Southeastern Connecticut Water Authority" on Justia Law

The Supreme Court reversed in part the judgment of the trial court finding Defendant guilty of manslaughter in the first degree with a firearm and other offenses, holding that the trial court improperly admitted certain evidence.On appeal, Defendant argued that his statements to the police were improperly admitted into evidence because his constitutional rights were violated when the police continued to question him after he invoked his right to counsel pursuant to Miranda v. Arizona, 384 U.S. 436 (1966). Defendant further argued that the prosecutor committed improprieties during closing argument, depriving him of his right to a fair trial. The Supreme Court affirmed, holding (1) the admission of Defendant's written statement and a portion of a video recording of the interview with police should have been suppressed, and the error was not harmless as to Defendant's conviction of manslaughter in the first degree with a firearm; and (2) there was no other reversible error in this case. View "State v. Culbreath" on Justia Law

The Supreme Court reversed in part the judgment of the appellate court affirming Defendant's conviction of criminal possession of a pistol or revolver in violation of Conn. Gen. Stat. 53a-217c, holding that the appellate court erred in concluding that there was sufficient evidence to support the conviction.On appeal, Defendant claimed that there was insufficient evidence of his knowledge of the gun and no evidence to prove his dominion or control over it. The appellate court affirmed, concluding that there was sufficient circumstantial evidence to support the conviction. The Supreme Court reversed in part, holding that the evidence was insufficient to establish beyond a reasonable doubt that Defendant had knowledge of the gun and the intent to exercise dominion or control over it. View "State v. Dawson" on Justia Law

The Supreme Court affirmed the judgment of the trial court concluding that Boardwalk Realty Associates, LLC (Boardwalk), the court-appointed receiver of rents, lacked authority under Conn. Gen. Stat. 12-163a to impose and collect rent or use and occupancy payments in the place of the subject property's owner, Cadle Properties of Connecticut, Inc., holding that there was no error.This case centered on the Town of Canton's efforts to collect unpaid property taxes on a parcel of real property that was effectively abandoned Cadle and on which M&S Gateway Associates, LLC and Mitchell Volkswagen, LLC (together, Defendants) operated an automobile dealership. Boardwalk brought a complaint seeking rent and use and occupancy payments from Defendants. The trial court granted summary judgment in favor of Defendants, holding that section 12-163a does not permit a receiver of rents to collect rent or use and occupancy payments if the tax delinquent property owner is absent and nor pursuing those payments. The Supreme Court affirmed, holding that a receiver appointed under section 12-163a is not statutorily authorized to impose and collect rent or use and occupancy payments under the facts and circumstances of this case. View "Boardwalk Realty Associates, LLC v. M & S Gateway Associates, LLC" on Justia Law