Justia Connecticut Supreme Court Opinion Summaries

The Supreme Court overruled Savage v. St. Aeden’s Church, 189 A. 599 (Conn. 1937), insofar as it concluded that an employee is entitled to compensation as a matter of law when, during the course of the employee's employment, he or she is injured due to an idiopathic fall onto a level floor.The Appellate Court reversed the decision of the Compensation Review Board (Board) affirming the decision of the Workers' Compensation Commissioner for the Second District (Commissioner) denying Plaintiff's application for benefits filed after she suffered a syncopal episode at her workplace, which caused her to fall backward and strike her head on the ground, concluding that, under Savage, Plaintiff's injury was compensable as a matter of law. The Supreme Court reversed after overruling the portion of Savage at issue, holding that the risk or condition must be "peculiar to the employment" for the injury to be compensable. View "Clements v. Aramark Corp." on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the trial court convicting Defendant of one count of intentional assault and one count of reckless assault, holding that the appellate court correctly concluded that the jury's verdicts of guilty of intentional assault and reckless assault were not legally erroneous.On appeal, Defendant argued that the verdicts finding him guilty of intentional assault and reckless assault were legally inconsistent because their requisite mental states of intentional and reckless were mutually exclusive. The appellate court concluded that the convictions were consistent because each mental state pertains to a different result. The Supreme Court affirmed, holding that the jury reasonably could have found that Defendant intended to cause the victim serious physical injury and simultaneously disregarded the risk that his conduct would cause the victim's death. View "State v. Alicea" on Justia Law

The Supreme Court reversed the judgment of the appellate court dismissing Defendant's appeal from the trial court's denial of her motion to open the judgment of strict foreclosure, holding that the trial court did not abuse its discretion by denying the motion.Defendant defaulted on a promissory note, and Plaintiff commenced a strict foreclosure action. After the trial court set the law day, Defendant filed a motion to open the judgment, raising equitable grounds involving alleged misrepresentations by Plaintiff relating to the foreclosure proceedings. The trial court denied the motion. The appellate court dismissed Defendant's appeal as moot. The Supreme Court reversed, holding (1) the claim raised in Defendant's motion was not moot but, rather, was a recognizable claim in equity; and (2) Defendant's claim that the trial court abused its discretion by denying her motion to open the judgment failed. View "U.S. Bank National Ass'n v. Rothermel" on Justia Law

The Supreme Court affirmed Defendant's conviction of two counts of sexual assault in the first degree and two counts of risk of injury to a child, holding that there was no error in the proceedings below.On appeal, Defendant asserted that the trial court erred in admitting evidence of the victim's out-of-court demeanor and that the prosecutor made improper remarks during rebuttal and closing argument. The Supreme Court affirmed, holding (1) the allegedly improper admission of the victim's demeanor testimony was harmless; and (2) two of the prosecutor's remarks made during closing argument and rebuttal were improper, but these improprieties did not deprive Defendant of a fair trial. View "State v. Courtney G." on Justia Law

The Supreme Court reversed the judgment of the habeas court denying Petitioner's amended petition for a writ of habeas corpus, holding that Petitioner's classification as a sex offender violated his right to procedural due process under both the federal constitution and Conn. Const. art. I, 9.In his habeas corpus petition, Petitioner alleged that the Commissioner of Correction violated his right to procedural due process in classifying him as a sex offender and that the habeas court erred in determining that the challenged classification did not violate his right to substantive due process or his right not to be punished "except in cases clearly warranted by law," under article first, section nine. The Supreme Court reversed, holding that Petitioner's classification as a sex offender violated his right to procedural due process. View "Anthony A. v. Commissioner of Correction" on Justia Law

The Supreme Court reversed the judgment of the appellate court affirming the judgments of the trial court dismissing Plaintiff's appeals challenging various text amendments to the Hartford Zoning Regulations and zoning map changes made by the City of Hartford's Planning and Zoning Commission, holding that the appellate court erred.Plaintiff applied for a special permit to construct a restaurant on property that it owned in the City. Thereafter, Plaintiff filed four separate appeals challenging the City's zoning map changes which, if properly adopted, would effectively preclude Plaintiff from obtaining the special permit. The trial court dismissed the appeal on the ground that Plaintiff had failed to exhaust its administrative remedies. The appellate court affirmed. The Supreme Court reversed, holding (1) the appellate court erred in determining that the City's zoning administrator had the authority to void Plaintiff's application for a special permit; and (2) Plaintiff could not have appealed the zoning administrator's action to the zoning board of appeals because it was not a legal decision for purposes of Conn. Gen. Stat. 8-6. View "Farmington-Girard, LLC v. Planning & Zoning Commission of City of Hartford" on Justia Law

The Supreme Court reversed the judgment of the appellate court affirming Defendant's conviction of risk of injury to a child, holding that the trial court abused its discretion by limiting Defendant's direct examination of himself and that the error was harmful.During trial, Defendant represented himself. On appeal, Defendant argued that the trial court erred in excluding testimony pertaining to his justification defense. The appellate court affirmed the convictions. The Supreme Court reversed, holding that the trial court abused its discretion in precluding Defendant's testimony, in which he attempted to testify about information crucial to his justification defense, and that the error was harmful. View "State v. Mark T." on Justia Law

The Supreme Court affirmed the judgment of the appellate court affirming Defendant's conviction of murder and related offenses, holding that the appellate court correctly concluded that the trial court's rejection of Defendant's insanity defense was reasonable.On appeal, Defendant argued that the trial court improperly rejected the opinions of his experts. Specifically, Defendant argued that the State neither presented nor elicited evidence to undermine the consensus of his experts that, as the result of a mental disease, Defendant lacked substantial capacity to control his conduct within the requirements of the law. The appellate court affirmed. The Supreme Court affirmed, holding that the appellate court did not err in concluding that the trial court's rejection of his expert opinion was not arbitrary. View "State v. Weathers" on Justia Law

The Supreme Court affirmed the judgment of the appellate court concluding that the assessor for Defendant, the town of Wilton, improperly imposed late filing penalties on Plaintiffs after taking and subscribing to the oath on the grand list for that assessment year, holding that there was no error.This dispute arose because the assessor signed the grand list without imposing penalties on Plaintiffs and instead delayed imposing penalties until when the assessor issued certificates of change pursuant to Conn. Gen. Stat. 12-60 for the properties that were the subjects of the penalties. The Board of Assessment Appeals of the Town of Wilton denied Plaintiffs' appeals. The trial court affirmed. The appellate court reversed, holding that tax penalties imposed without statutory authority are invalid. The Supreme Court affirmed, holding (1) the penalties imposed were assessments required by law within the meaning of Conn. Gen. Stat. 12-60; and (2) because penalties imposed without statutory authority are invalid, the Town may not collect the penalties at issue in this case. View "Wilton Campus 1691, LLC v. Wilton" on Justia Law

The Supreme Court reversed in part the judgment of the trial court sustaining Plaintiffs' administrative appeal and remanding this case to the Commissioner of Banking for further proceedings as to Plaintiffs' entitlement to tribal sovereign immunity in administrative proceedings, holding that the trial court erred in part.At issue was whether a business entity shared sovereign immunity with Otoe-Missouria Tribe of Indians, a federally-recognized tribe. On appeal, Plaintiffs - Clear Creek Lending, Great Plains Lending, LLC, and John Shotton, chairman of the Tribe - claimed that the trial court improperly allocated the burden of proving entitlement to tribal sovereign immunity to Plaintiffs, improperly required proof of a functioning relationship between the entities and the tribe, and improperly failed to find Shotton immune in further administrative proceedings. The Supreme Court reversed in part, holding (1) the entity claiming arm of the tribe status bears the burden of proving its entitlement to that status; (2) Great Plains was an arm of the tribe and Shotton was entitled to tribal sovereign immunity but not injunctive relief; and (3) there was insufficient evidence that Clear Creek was an arm of the tribe as a matter of law. View "Great Plains Lending, LLC v. Department of Banking" on Justia Law