Justia Connecticut Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the trial court revoking Defendant's probation and sentencing him to an effective term of imprisonment of two years, holding that the trial court did not err in denying Defendant's motion to dismiss the violation of probation charge.Defendant pleaded guilty to illegal possession of child pornography in the second degree. After Defendant was released on probation he was charged with violating his probation for failing to complete sex offender treatment. The trial court found that Defendant had violated his probation, revoked his probation, and sentenced him to a term of imprisonment of six years. Defendant appealed, arguing that the condition of probation on which the violation of probation charge was predicated violated his Fourteenth Amendment rights to due process and equal protection and the constitutional prohibition against the imposition of cruel and unusual punishment. The Supreme Court affirmed, holding that Defendant's claims of error lacked merit. View "State v. Imperiale" on Justia Law

The Supreme Court affirmed the judgments of the trial court applying the general negligence statute of limitations in Conn. Gen. Stat. 52-584 to Plaintiffs' claims alleging medical negligence instead of the extended limitation period set forth in section 52-577d, holding that the trial court did not err.Plaintiffs were minor patients of Robert Rackliffe, a pediatrician practicing in the early 1970s to the 1980s. Plaintiffs alleged that Rackliffe sexually assaulted them during their annual physical examinations and that Rackliffe's conduct constituted medical negligence. The trial court granted summary judgment in favor of Defendant. The Supreme Court affirmed, holding that section 52-577d did not apply to Plaintiffs' claims sounding in negligence and that the negligence claims were governed by the limitation period set forth in section 52-584. View "Doe v. Rackliffe" on Justia Law

The Supreme Court reversed the judgment of the appellate court reversing the judgment of the trial court convicting Defendant of burglary in the third degree, attempt to commit tampering with physical evidence, and attempt to commit arson in the second degree, holding that the appellate court improperly addressed an issue of evidentiary sufficiency sua sponte without calling for supplemental briefing.The appellate court reversed Defendant's conviction on the ground that there was insufficient evidence for the jury to have reasonably concluded that Defendant intended to tamper with physical evidence. The Supreme Court reversed, holding that the appellate court improperly decided an issue of evidentiary sufficiency sue sponte without ordering supplemental briefing, as required by Blumberg Associates Worldwide, Inc. v. Brown & Brown of Connecticut, Inc., 84 A.3d 840 (Conn. 2014). View "State v. Stephenson" on Justia Law

The Supreme Court reversed the judgment of the appellate court affirming Defendant's conviction of assault in the second degree, holding that the appellate court erred in determining that the trial court's investigative inadequacy jury instruction did not mislead the jury or otherwise deprive Defendant of his right to present an investigative inadequacy defense.The jury found Defendant guilty of assault in the second degree, and the court rendered judgment in accordance with the verdict. On appeal, Defendant argued that the jury instructions deprived him of his right to present a defense of investigative inadequacy. The appellate court rejected Defendant's claim and affirmed. The Supreme Court reversed, holding (1) the model jury instruction utilized by the trial court in this case failed properly to instruct the jury; and (2) the instructional error was not harmless. View "State v. Gomes" on Justia Law

In this action for a temporary injunction in connection with the intake and discharge of water from the Long Island Sound and nearby bodies of water by Dominion Nuclear Connecticut, Inc., the owner and operator of a nuclear power station, the Supreme Court ultimately affirmed the judgments in favor of Defendants, holding that the trial court did not err.This case was before the Supreme Court for the third time. Plaintiff brought this action under the Connecticut Environmental Protection Act of 1971 (CEPA), Conn. Gen. Stat. 22a-14 et seq., against Dominion and the Department of Environmental Protection, challenging the Department's decision to issue a National Pollutant Discharge Elimination system permit to Dominion to authorize the intake and discharge of water by the plant, arguing that the permit renewal proceeding was inadequate. On remand for the second time from the Supreme Court, the trial court rendered judgment in favor of Defendants. The Supreme Court affirmed, holding (1) the administrative proceeding was not inadequate; and (2) Plaintiff's remaining claims on appeal were inadequately briefed. View "Burton v. Department of Environmental Protection" on Justia Law

The Supreme Court reversed the judgment of the appellate court concluding that Conn. Gen. Stat. 14-55 was not repealed by a sequence of contradictory public acts relating to that statute, holding that section 14-55 has not been repealed.Plaintiff filed an administrative appeal challenging the decision of the Zoning Board of Appeals of the City of Stamford to grant a certificate of approval of the location for Defendants' used car dealership. The trial court denied the administrative appeal, but the appellate court reversed. At issue was whether the suitability analysis mandated by section 14-55 was still required in order to obtain a certificate of approval for the location of a used car dealership, despite subsequent revisions of the General Statutes listing that provision as having been repealed. The Supreme Court reversed, holding that the appellate court erred in concluding that section 14-55 had been repealed. View "One Elmcroft Stamford, LLC v. Zoning Board of Appeals" on Justia Law

The Supreme Court affirmed the judgment of the appellate court determining that Public Acts, Spec. Session, June 2015, No. 15-2, 1 (Spec. Sess. P.A. 15-2) does not apply retroactively, holding that the plain language of Spec. Sess. P.A. 15-2, 1 clearly and unambiguously prohibits retroactive application.Defendant was found guilty of one count of possession of less than four ounces of a cannabis-type substance and of two counts of possession of narcotics. Defendant filed a motion to correct an illegal sentence, which the trial court denied. The appellate court affirmed. Defendant appealed, arguing that a prospective-only application of the amendment would lead to an absurd or unworkable result and, alternatively, that the Supreme Court should adopt the amelioration doctrine. The Supreme Court affirmed and declined the invitation to adopt the amelioration doctrine, holding that the amendment does not apply retroactively and that this conclusion does not lead to an absurd or unworkable result. View "State v. Bischoff" on Justia Law

The Supreme Court reversed the judgment of the appellate court affirming the judgment of the trial court denying Defendant's motion to correct an illegal sentence, holding that the trial court lacked subject matter jurisdiction to entertain Defendant's motion because the motion sought only to modify Defendant's conviction, not his sentence.Defendant was convicted of felony murder and manslaughter. The trial court merged the conviction for manslaughter with the felony murder conviction for sentencing purposes. In his motion to correct an illegal sentence, Defendant argued that his sentence was illegal under the supervisory rule set forth in State v. Polanco, 61 A.3d 1084 (2013). The trial court concluded that Polanco did not apply retroactively and denied the motion. The appellate court affirmed. The Supreme Court reversed, holding that the trial court lacked jurisdiction to entertain Defendant's motion to correct an illegal sentence. View "State v. Smith" on Justia Law

The Supreme Court affirmed the judgment of the trial court in favor of Defendant, Denise Merrill, Secretary of the State, intros action seeking declaratory and injunctive relief with respect to Defendant's change of the absentee ballot application for the August 11, 2020 primary election to add COVID-19 as a new reason for requesting an absentee ballot pursuant to Executive Order No. 7QQ, holding that the trial court did not err.At issue in this public interest appeal was whether Governor Ned Lamont's executive order, which was later ratified by the legislature and which modified Conn. Gen. Stat. 9-135 by adding COVID-19 as a permissible reason for absentee voting violates Conn. Const. art. VI, 7. The trial court granted jumtgnet for Defendant. The Supreme Court affirmed, holding that Executive Order No. 7QQ does not violate Article 6, Section 7. View "Fay v. Merrill" on Justia Law

The Supreme Court reversed the judgment of the appellate court affirming Defendant's conviction of assault in the second degree, holding that the appellate court erred in determining that a challenged jury instruction did not mislead the jury or otherwise deprive Defendant of his right to present an investigative inadequacy defense.At trial, Defendant's main defense was that the police had conducted an inadequate investigation of the incident leading to his conviction. On appeal, Defendant claimed that the jury instructions deprived him of his right to present his defense. The appellate court affirmed, holding that the trial court's jury instruction on investigative inadequacy was consistent with investigative inadequacy instructions approved by the Supreme Court. The Supreme Court reversed, holding that the model jury instruction utilized by the court in this case may have misled the jury or otherwise deprived Defendant of his right to present an investigative inadequacy defense. View "State v. Gomes" on Justia Law