Justia Connecticut Supreme Court Opinion Summaries

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

The Supreme Court affirmed the judgment of the appellate court affirming the trial court's determination that Susan D. Elia could not create an irrevocable trust on her own behalf while she was under a voluntary conservatorship, holding that there was no error.In 2011, the probate court granted Elia's application for voluntary representation by Renee Seblatnigg as the conservator of Elia's estate. Elia subsequently created an irrevocable trust and arranged for the transfer of assets to it. In 2014, Margaret Day, acting in her capacity as coconservator of Elia's estate, brought this action seeking a judgment that the trust was void ab initio because Seblatnigg, acting in her capacity as Elia's conservator, did not create and fund the trust with the approval of the probate court under R.I. Gen. Stat. 45a-655. The trial court granted summary judgment for Day, and the appellate court affirmed. The Supreme Court affirmed, holding that the appellate court correctly determined that Elia lacked the legal authority to establish the irrevocable trust and, consequently, that the trust was void ab initio. View "Day v. Seblatnigg" on Justia Law

The Supreme Court reversed the judgment of the trial court determining that Defendant had engaged in criminal conduct while he was on probation by possessing a firearm that was capable of discharging a shot and thus revoking Defendant's probation, holding that the evidence was insufficient to establish that the airlift pellet gun found in Defendant's residence was a firearm as defined by Conn. Gen. Stat. 53a-3(19).At issue was whether the State presented sufficient evidence at the violation of probation hearing in this case to establish that the airlift pellet gun found in Defendant's residence fell under the definition of a firearm. The Supreme Court concluded that it did not, holding that the trial court's factual finding that the airlift pellet gun was a "weapon" capable of firing a shot for the purpose of the definition of "firearm" under section 53a-3(19) was clearly erroneous. View "State v. Lopez" on Justia Law

The Supreme Court affirmed the judgment of the appellate court affirming the judgment in favor of Defendant Theresa Virgulak in this action brought by Plaintiff, Manufacturers and Traders Trust Company, holding that there was no error.The trial court found in favor of Defendant on Plaintiff's foreclosure, reformation, and unjust enrichment claims. The appellate court affirmed. The Supreme Court affirmed, holding (1) the trial court properly declined Plaintiff’s request to reform the mortgage deed to reference that the mortgage deed executed by Defendant was given to secure a note executed by her husband; and (2) the trial court correctly determined that Plaintiff was not entitled to foreclose the mortgage executed by Defendant because Defendant was not a borrower on the note. View "JPMorgan Chase Bank, National Ass'n v. Virgulak" on Justia Law

The Supreme Court affirmed the judgment of the trial court concluding that the accidental failure of suit statute, Conn. Gen. Stat. 52-592, did not save the otherwise time-barred action of Plaintiff, executrix of the estate of Theresa Riccio, holding that there was no error.The trial court concluded that Plaintiff's wrongful death action was time barred because her first medical malpractice action was dismissed due to her attorney's gross negligence for failing to file with the complaint legally sufficient medical opinion letters, as required by Conn. Gen. Stat. 52-190a(a) and two appellate court decisions interpreting section 52-190a(a). The appellate court dismissed the appeal, concluding that the action was time barred. The Supreme Court affirmed, holding that the trial court did not err in determining that the omission of the experts' qualifications was egregious conduct rather than a matter of form or mistake. View "Riccio v. Bristol Hospital, Inc." on Justia Law