Justia Connecticut Supreme Court Opinion Summaries

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

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