Justia Connecticut Supreme Court Opinion Summaries

The Supreme Court reversed the judgment of the trial court dismissing Plaintiffs' administrative appeal for lack of subject matter jurisdiction from the adverse decision of the State Elections Enforcement Commission determining that Plaintiffs violated certain state election laws and regulations, holding that the administrative appeal was timely filed.In its decision, the Commission found that Plaintiffs, who had received funding for their campaigns through the Citizens' Election Program, had violated laws and regulations related to the Program and imposed civil fines for those violations. Plaintiffs appealed. The superior court dismissed the appeal on the ground that it was untimely filed under Conn. Gen. Stat. 4-183(c)(2). The Supreme Court reversed, holding (1) the timeliness of Plaintiffs' appeal was governed by the limitation period of Conn. Gen. Stat. 4-183(c)(3); and (2) Plaintiffs' appeal was timely filed under section 4-183(c)(3). View "Markley v. State Elections Enforcement Commission" on Justia Law

The Supreme Court affirmed the judgment of the appellate court reversing the judgment of the habeas court denying Appellant's petition for a writ of habeas corpus and ordering a new trial on certain charges, holding that the trial court committed an error under State v. Salomon, 949 A.2d 1092 (Conn. 2008), and that the error was not harmless.At issue in this appeal and the companion case decided today, see Banks v. Commissioner of Correction, __ A.3d __ (Conn. 2021), was how the harmlessness of a Salamon error is to be assessed. In Salamon, the Supreme Court held that, when a defendant is charged with kidnapping in conjunction with another underlying crime, the defendant is entitled to a jury instruction that he cannot be convicted of kidnapping if the restraint imposed on the victim was merely incidental or necessary to the underlying crime. Here, Appellant forcibly moved and restrained his victims after having taken property in their possession. The Supreme Court affirmed the judgment of the appellate court granting Appellant's habeas petition and ordering a new trial on the kidnapping charges, holding that this Court had no fair assurance that the Salamon error in this case did not have a substantial and injurious effect or influence in determining the jury's verdict. View "Bell v. Commissioner of Correction" on Justia Law

In this case, the Supreme Court resolved two questions left open by State v. Salamon, 949 A.2d 1092 (Conn. 2008) and its progeny, holding that that standard articulated in Brecht v. Abrahamson, 507 U.S. 6019 (1993), which governs federal habeas actions, applies in state habeas proceedings as well.In Salamon, the Supreme Court overruled its longstanding interpretation of Connecticut's kidnapping statutes and held that, when a defendant is charged with kidnapping in conjunction with another underlying crime, the defendant is entitled to a jury instruction that he cannot be convicted of kidnapping if the restraint imposed on the victim was merely incidental or necessary to the underlying crime. In the instant case, Appellant was found guilty of four counts of kidnapping in the first degree and four counts of robbery. After the Supreme Court decided Salamon, Appellant filed a petition for a writ of habeas corpus arguing that the instructions given to the jury were not in accordance with Salamon. The habeas court denied the petition. The appellate court reversed. The Supreme Court affirmed, holding (1) the Brecht standard applied in this case; and (2) the habeas court correctly determined that the trial court's failure to instruct Appellant's jury in accordance with Salamon was harmless. View "Banks v. Commissioner of Correction" on Justia Law

In this case coming to the Supreme Court on certification from a federal district court, the Court was asked to decide questions regarding Conn. Gen. Stat. 52-572g. The Court answered the questions as follows: (1) "the amount of indebtedness then outstanding in connection with the credit transaction" is the amount of indebtedness outstanding at the time of the buyer's written demand on the seller for purposes of limiting an assignee's liability under section 52-572g; (2) an assignee can avoid liability under the statute only if the promissory note, contract, or other instrument is reassigned back to the seller prior to the buyer making such a demand; and (3) if a retail installment contract includes the Federal Trade Commission "holder rule" language mandated by 16 C.F.R. 433.2, an assignee's liability under that rule is cumulative to its liability under section 52-572g. View "Hernandez v. Apple Auto Wholesalers of Waterbury, LLC" on Justia Law

The Supreme Court reversed in part the judgment of the trial court awarding postjudgment, offer of compromise interest to Plaintiff under Conn. Gen. Stat. 52-192a and Practice Book 17-18, holding that the trial court's award of postjudgment, offer of compromise interest was improper.Plaintiff, an employment staffing agency that providers workers for temporary assignments, commenced this action against Defendant to recover a debt by filing a complaint for breach of contract and unjust enrichment. The trial court entered judgment in favor of Plaintiff and awarded Plaintiff interest. On appeal, Defendant argued that the trial court's award of postjudgment interest under section 52-192a and Practice Book 17-18 was improper. The Supreme Court reversed the judgment as to the award of postjudgment interest under section 52-192a, holding that the award of post judgment, offer of compromise interest was improper under Gionfriddo v. Avis Rent A Car system, Inc., 472 A.2d 316 (Conn. 1984). View "Kelly Services, Inc. v. Senior Network, Inc." on Justia Law

The Supreme Court affirmed the order of the appellate court concluding that the trial court had abused its discretion in awarding Plaintiff $18,000 per month in permanent, nonmodifiable alimony, holding that the award constituted an abuse of discretion.On appeal, Defendant argued that the trial court's orders impermissibly double counted his income by considering it for business valuation purposes and further by awarding alimony on the basis of his income from those businesses. The appellate court agreed and reversed the judgment as to the trial court's financial orders and remanded the case for a new hearing on all financial issues. The Supreme Court affirmed in part and reversed in part, holding (1) the alimony award was an abuse of discretion; and (2) this Court's rule against double counting does not apply when, as in the instant case, the asset at issue is the value of a business. View "Oudheusden v. Oudheusden" on Justia Law

The Supreme Court affirmed Defendant's conviction of two counts of interfering with an officer, in violation of Conn. Gen. Stat. 53a-167a(a), holding that there was no error in the proceedings below.At issue on appeal was whether the trial court erred in denying Defendant's pretrial motion to suppress on the grounds that he was seized in violation of the Fourth Amendment when a marked police cruiser blocked the egress of his vehicle, which was parked with its engine running and Defendant asleep in the driver's seat. The Supreme Court affirmed, holding that no violation of the Fourth Amendment occurred because the responding officer was checking on Defendant's well-being pursuant to the officer's community caretaking function and was not engaged in an investigatory stop involving criminal activity. View "State v. Pompei" on Justia Law

The Supreme Court affirmed Defendant's conviction of three counts of first degree sexual assault and three counts of risk of injury to a child, holding that there was no error in the proceedings below.Specifically, the Supreme Court held (1) the prosecutor did not engage in prosecutorial impropriety in her questioning of the victim; (2) the prosecutor did not engage in prosecutorial impropriety during closing and rebuttal arguments; and (3) the trial court did not violate Conn. Gen. Stat. 54-84(b) or infringe on Defendant's constitutional right to remain silent when it denied his request to instruct the jury that he elected not to testify and instead referred to his failure to testify. View "State v. Michael T." on Justia Law

The Supreme Court reversed the judgment of the appellate court reversing decision the judgment of trial court and directing summary judgment for the Town of Ledyard, holding that the ambit of Conn. Gen. Stat. 12-161a includes a directly related federal action that is determinative of a municipality's authority to pursue the underlying state collection proceeding.The Town brought a complaint to collect unpaid taxes for gaming equipment leased by WMS Gaming, Inc. to the Mashantucket Pequot Tribal Nation, for its gaming operations. The Tribal Nation responded by filing a second action in the federal court challenging the Town's authority to impose the taxes. The parties eventually executed a stipulation and motions for summary judgment as to liability only with respect to the federal action attorney's fees. The trial court concluded that the Town was liable for the federal action attorney fees pursuant to section 12-161a. The appellate court reversed, construing section 12-161a to conclude that the Town's liability for attorney's fees under the statute was limited to the collection proceeding in state court and did not include the related federal court proceeding. The Supreme Court reversed, holding that WMS Gaming was entitled to reasonable attorney's fees within the meaning of section 12-161a. View "Ledyard v. WMS Gaming, Inc." on Justia Law

The Supreme Court affirmed the judgment of the appellate court affirming the judgment of the superior court dismissing as untimely Plaintiff's application to vacate an arbitration award, holding that the thirty-day limitation period set forth in Conn. Gen. Stat. 52-420(b) applied to Plaintiff's application to vacate.The trial court concluded that Plaintiff's application to vacate an arbitration award rendered in favor of Defendants was untimely under section 52-420(b) because the application was filed more than thirty days after Plaintiff received notice of the arbitration award. The appellate court affirmed. On appeal, Plaintiff argued that the appellate court erred in concluding that its application to vacate the arbitration award was governed by section 52-420(b), in contravention of a private agreement between the parties. The Supreme Court affirmed, holding that the trial court properly held that section 52-420(b) applied to Plaintiff's application to vacate. View "A Better Way Wholesale Autos, Inc. v. Saint Paul" on Justia Law