Justia Connecticut Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the trial court concluding that Conn. Gen. Stat. 7-464, as amended by section 1 of No. 17-165 of the 2017 Public Acts (P.A. 17-165), did not authority the City of Waterbury's lien in this case, holding that there was no error.Plaintiff, an employee of the City, which is a self-insured municipality, was injured in a motor vehicle accident. The City paid for Plaintiff's medical care resulting from his injuries. After Plaintiff initiated an action against the third-party tortfeasor who caused the accident, the City filed a notice of lien with Plaintiff's attorney, claiming a right to reimbursement of the medical expenses it had paid. Plaintiff subsequently settled his civil action and brought this action contesting the validity of the City's lien on the proceeds of his settlement. The trial court granted Plaintiff's motion for summary judgment, concluding that P.A. 17-165 did not apply retroactively to pending actions, such as Plaintiff's. The Supreme Court affirmed, holding that the trial court correctly determined that the City's lien stemmed from an improper, retroactive application of P.A. 17-165. View "Maghfour v. Waterbury" on Justia Law

In this case arising from the sexual abuse of Plaintiffs by Allison Marchese, an English teacher at their high school, the Supreme Court affirmed the judgments of the trial court granting summary judgment in favor of Defendants on the ground of governmental immunity, holding that there was no error.Plaintiffs brought this action for damages against the town of Madison, the town's Board of Education, and the principal of the Daniel Hand High School, pursuant to the municipal liability statute, Conn. Gen. Stat. 52-557n, claiming that they were injured by Defendants' failure to prevent and/or interrupt Marchese's inappropriate relationship with Plaintiffs and to report Marchese's conduct to the proper authorities. The trial court granted Defendants' motions for summary judgment. The Supreme Court affirmed, holding that the trial court properly granted Defendants' motions for summary judgment. View "Doe v. Madison" on Justia Law

The Supreme Court affirmed Defendant's conviction of sexual assault in the third degree, sexual assault in the fourth degree, risk of injury to a child, and sexual assault in the first degree, holding that Defendant's claims on appeal lacked merit.Specifically, the Supreme Court held that (1) the trial court did not abuse its discretion in admitting into evidence a video recording of the victim's forensic interview under the medical treatment exception to the hearsay rule; (2) alleged prosecutorial impropriety did not deprive Defendant of a fair trial; (3) the evidence was sufficient to support the convictions; and (4) the statutes criminalizing sexual assault in the first degree and risk of injury to a child are not unconstitutionally vague as applied to Defendant's conduct. View "State v. Roy D. L." on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the trial court concluding that the Town of Fairfield may require James Gallagher and his wife to enroll in medicare but may also reimburse the costs of their Medicare Part B premiums, holding that the Town was not required to reimburse the Gallaghers for their Medicare premium costs.In 1985, when federal law did not permit municipal employees to participate in the Medicare system, the Town and its police union entered into a collective bargaining agreement providing that upon members who retired early, such as James, due to disability and their eligible dependents would be entitled to Town-paid private health insurance. An intervening change in federal law permitted retirees, such as James, to enroll in Medicare upon reaching the age of sixty-five. At issue was whether the Town was permitted to terminate James's private health insurance, provide him with comparable Town-paid Medicare supplemental insurance, and require that he bear the costs of his Medicare premium. The Supreme Court held that the trial court (1) properly concluded that the Town may require the Gallaghers to enroll in Medicare; but (2) erred in concluding that the Town must also reimburse the costs of the Gallaghers' Medicare premium costs. View "Gallagher v. Fairfield" on Justia Law

The Supreme Court affirmed the judgment of the trial court rendered in favor of Defendants, various city election officials and the secretary of state, in this election contest, holding that Plaintiff's arguments on appeal were unavailing.Plaintiff claimed that she ran in the November 2020 election to fill a vacancy on the Board of Education of the City of Stamford, that she won the election, and that the City's election officials improperly refused to credit the election results on the ground that the Stamford Charter provides that the charter provides that the election to fill the vacancy could not be held until the "next biennial election" in 2021. The trial court entered judgment for Defendants. The Supreme Court affirmed, holding (1) this Court refuses to construe the phrase "next biennial election" to mean "next city election"; and (2) a charter provision limiting vacancy elections to odd-numbered years did not violate the First Amendment and that the City's failure to validate the votes at issue did not disenfranchise Plaintiff. View "O'Shea v. Scherban" on Justia Law

The Supreme Court affirmed in part and reversed in part Defendant's convictions on charges arising from two separate incidents between him and officers of the Clinton Police Department in July 2015, holding that Defendant's conviction in the case relating to events of July 19, 2015 must be reversed and the conviction in the case relating to the events of July 22, 2015 is reversed with respect to one assault count.On appeal, Defendant argued (1) evidence of certain events during the first incident should have been suppressed because those events were the result of an unconstitutional investigatory detention, and (2) his convictions of two counts of assault of public safety personnel related to the second incident was infirm because the evidence was insufficient and the trial court erred in instructing the jury. The Supreme Court reversed in part, holding (1) the trial court erred in denying Defendant's motion to suppress; and (2) a new trial was required with respect to one of the assault charges due to instructional error. View "State v. Haughwout" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of murder, criminal attempt to commit robbery in the first degree, conspiracy to commit robbery in the first degree, and criminal possession of a firearm, holding that the trial court did not err in denying Defendant's motions to suppress.In his suppression motions, Defendant sought to suppress (1) the firearm and related evidence seized from his residence, which evidence he argued was discovered as a result of an unlawful search, and (2) the incriminating statements he made during an interrogation at the police station, claiming the statements were made involuntarily. The Supreme Court affirmed the denial of Defendant's motions to suppress, holding (1) the trial court properly Defendant's motion to suppress the evidence obtained during the search of his residence; and (2) Defendant's statements were voluntary, and the trial court properly admitted them into evidence at trial. View "State v. Griffin" on Justia Law

The Supreme Court affirmed the decision of the appellate court upholding the trial court's judgment of conviction in this case, holding that there was sufficient evidence for the jury to find Defendant guilty of murder.After his first two trials ended in mistrials after hung juries Defendant was convicted of murder. On appeal, Defendant argued that the jury lacked sufficient evidence to find him guilty of murder because the State failed to prove the manner, means, place, cause, and time of death. The appellate court affirmed. The Supreme Court affirmed, holding that the evidence supported Defendant's conviction of murder. View "State v. Richards" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of one count of murder with special circumstances and imposing a mandatory sentence under Conn. Gen. Stat. 53a-35a(1)(B) of life imprisonment without the possibility of release, holding that there was no error in the proceedings below.Specifically, the Supreme Court held that the trial court (1) correctly instructed the jury on the "in the course of a single transaction" element of murder with special circumstances; (2) did not commit plain error by failing to provide the jury, sua sponte, with a special credibility instruction with respect to one of the State’s witnesses, who Defendant claimed was the actual perpetrator of the murders; and (3) did not violate Defendant's state and federal constitutional rights to counsel and to present a defense by precluding defense counsel from making a certain argument in closing argument. View "State v. Silva" on Justia Law

The Supreme Court reversed the order of the trial court requiring Defendant to submit both to an examination for sexually transmitted diseases pursuant to Conn. Gen. Stat. 54-102a(a) and to testing for human immunodeficiency virus (HIV) pursuant to section 54-102a(b), holding that the trial court erred.Defendant was charged with patronizing a prostitute who was the victim of human trafficking and conspiracy to commit trafficking in persons. The State subsequently filed a motion seeking a court order requiring Defendant to submit to the examination and testing at issue. Thereafter, several victims of Defendant's alleged misconduct filed similar motions. The trial court ordered Defendant to submit to the examination and testing. Defendant appealed. The Supreme Court reversed, holding (1) under Conn. Const. art. I, 7, the trial court must make a finding that either an examination pursuant to section 54-102a(a) or testing pursuant to section 54-102a(b), or both, would provide would provide useful, practical information; and (2) because the trial court did not apply this standard, the case must be remanded for a new hearing. View "State v. Bemer" on Justia Law