Justia Connecticut Supreme Court Opinion Summaries

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

The Supreme Court affirmed the judgment of the trial court concluding that Defendant, as a hospital, was not a product seller for purposes of imposing strict liability under the Connecticut Product Liability Act, Conn. Gen. Stat. 52-572m et seq., under the circumstances of this case, holding that the trial court did not err.Plaintiff brought this complaint alleging injuries arising from Defendant's violations of, among other things, the product liability act, the Connecticut Unfair Trade Practices Act (CUTPA), Conn. Gen. Stat. 42-110a et seq., and common law. The trial court granted summary judgment for Defendant, concluding that Defendant was not a product seller for purposes of imposing strict liability under the product liability act and that Plaintiff's CUTPA and common law claims were time barred. The Supreme Court affirmed, holding (1) because Defendant provided general information regarding various medical procedures on its website and did not significantly participate in placing the medical device at issue into the stream of commerce Defendant was not a product seller for purposes of imposing strict liability under the product liability act; and (2) the statutes of limitations governing Plaintiff's remaining claims were not tolled. View "Normandy v. American Medical Systems, Inc." on Justia Law

The Supreme Court affirmed the judgment of the appellate court that dismissed Petitioner's appeal from the order of the habeas court directing Petitioner to produce certain investigative materials contained in the file of his criminal defense attorneys, holding that there was no error.Petitioner pleaded guilty to murder and tampering with physical evidence. Petitioner later filed a petition for writ of habeas corpus, arguing that he had received ineffective assistance of counsel. Respondent filed a motion for the production of relevant materials from Petitioner's criminal defense and investigative files, which the habeas court granted. Petitioner appealed, and the appellate court dismissed the appeal for lack of a final judgment. The Supreme Court affirmed, holding that the appellate court properly dismissed Petitioner's appeal for lack of subject matter jurisdiction. View "Halladay v. Commissioner of Correction" on Justia Law

The Supreme Court reversed Defendant's conviction of one count of sexual assault in the first degree, holding that the trial court violated Defendant's Sixth Amendment right to the assistance of counsel.At issue on appeal was whether the trial court violated Defendant's constitutional right to effective assistance of counsel by precluding defense counsel from arguing during closing argument that the complainant, M., had planted physical evidence in an effort to prove her false allegations against Defendant. The Supreme Court agreed and reversed, holding that the trial court's limitation of the scope of defense counsel's closing argument deprived Defendant of his Sixth Amendment right to the assistance of counsel. View "State v. Robert R." on Justia Law

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