Justia Connecticut Supreme Court Opinion Summaries

The defendant was convicted of two counts of murder and one count of assault in the first degree, among other crimes, related to a shooting incident involving multiple victims. The defendant claimed self-defense and defense of others, arguing that he shot one of the victims, Wooten, because Wooten was an active shooter. The defendant also sought to admit evidence of another victim, Taylor's, prior arson conviction to demonstrate Taylor's violent character.At trial, the defendant testified that he shot Taylor and Wooten in self-defense and defense of others. The jury found the defendant guilty of all charges, rejecting his justification defenses. The trial court excluded evidence of Taylor's arson conviction, ruling that the defendant did not have a certified copy of the conviction.The Connecticut Supreme Court reviewed the case. The court held that the evidence was sufficient to defeat the defendant's claims of self-defense and defense of others regarding Wooten's murder. The court noted that the shootings of Taylor, Smith, and Wooten were part of a single, continuous episode. The jury could reasonably have found that Wooten was acting defensively to protect Smith from the defendant's unprovoked attack. The court also held that any error in excluding evidence of Taylor's arson conviction was harmless. The arson conviction did not necessarily involve a risk of harm to a person or violent physical conduct, and there was no evidence that Taylor was armed or the aggressor in the shootings. The court affirmed the trial court's judgment. View "State v. Johnson" on Justia Law

The case involves the dissolution of a marriage between the plaintiff and the defendant, who is a partner at a large law firm. The plaintiff sought joint custody, child support, alimony, and an equitable division of property. The trial court found that the defendant's interest in potential retirement payments from her law firm was too speculative to be considered marital property subject to equitable distribution. The court awarded the plaintiff alimony contingent on the defendant's employment status at her firm.The trial court determined that the defendant's interest in the retirement payments was a mere expectancy, as the firm could unilaterally reduce or eliminate these payments at any time. The court found that the defendant's interest involved too many variables and risks to be considered property. The court awarded the plaintiff $35,000 per month in alimony for the first twelve months, and $30,000 per month thereafter, contingent on the defendant's employment at the firm. If the defendant retired and received retirement payments, the alimony would be 25% of her net after-tax income from those payments.The Appellate Court affirmed the trial court's judgment, agreeing that the retirement payments were too speculative to be considered property and that the alimony award was within the trial court's discretion. The court noted that the trial court had considered all relevant factors, including the plaintiff's earning capacity and the defendant's financial situation, in crafting the alimony order.The Supreme Court of Connecticut affirmed the Appellate Court's judgment. The court held that the trial court correctly determined that the defendant's interest in the retirement payments was too speculative to constitute property for equitable distribution. The court also held that the trial court did not abuse its discretion in awarding alimony contingent on the defendant's employment at her firm, as the order was intended to provide the plaintiff with financial support while incentivizing him to seek employment. View "D. S. v. D. S." on Justia Law

The plaintiff, a roofing business owner, sought a judgment declaring that the defendant, a workers' compensation insurance carrier, was obligated to defend and indemnify him in connection with a claim filed by his employee. The trial court granted the plaintiff's motion for summary judgment, determining that the defendant did not effectively cancel the workers' compensation insurance policy. The court found that the conflicting notices provided by the defendant, including a noncooperation notice and a cancellation notice, did not constitute an unambiguous and unequivocal notice of cancellation.The Appellate Court reversed the trial court's judgment, concluding that the defendant effectively canceled the policy before the employee's injury by complying with the statutory requirements of § 31-348, which governs the reporting and cancellation of workers' compensation insurance policies. The plaintiff argued that the Appellate Court incorrectly concluded that the cancellation notice effectively canceled the policy.The Supreme Court of Connecticut reviewed the case and concluded that insurers must strictly comply with § 31-348 when canceling a workers' compensation insurance policy. However, compliance with the statute does not supplant an insurer's obligations under contract law, which requires that a notice of cancellation must be definite, certain, and unambiguous. The court held that the Appellate Court incorrectly limited its analysis to the statutory compliance and failed to consider all relevant communications between the parties.The Supreme Court found that the defendant's notice of cancellation was not objectively definite and certain due to the conflicting noncooperation and cancellation notices, which provided indefinite and ambiguous information about the status of the plaintiff's insurance coverage. Consequently, the Supreme Court reversed the judgment of the Appellate Court and remanded the case with direction to affirm the trial court's judgment in favor of the plaintiff. View "Napolitano v. Ace American Ins. Co." on Justia Law

The plaintiff, a former employee of the defendant, sustained a compensable injury to his lumbar spine in 1994 while working. He continued to work until his voluntary retirement in 2003, after which his condition worsened, leading to further medical treatment and surgery in 2013. In 2015, the plaintiff sought total incapacity benefits retroactive to his retirement. The workers’ compensation commissioner awarded him benefits starting from December 30, 2017, and for a three-month period following his 2013 surgery, but not from his retirement date in 2003.The defendant appealed to the Compensation Review Board, arguing that the commissioner misapplied the law by awarding benefits after unauthorized medical treatment and to a voluntarily retired claimant. The board affirmed the commissioner’s decision, finding the award of benefits appropriate under the statute.The defendant then appealed to the Appellate Court, which reversed the board’s decision. The Appellate Court concluded that the plaintiff was not eligible for total incapacity benefits because his incapacity occurred after his voluntary retirement and he had no intention of returning to the workforce.The Supreme Court of Connecticut reviewed the case and concluded that under the plain language of General Statutes § 31-307 (a), a claimant who sustains a compensable workplace injury is eligible for total incapacity benefits regardless of whether the incapacity occurs before or after voluntary retirement. The court reversed the Appellate Court’s judgment and remanded the case for consideration of the defendant’s alternative claim regarding the necessity and availability of the plaintiff’s 2013 surgery. View "Cochran v. Dept. of Transportation" on Justia Law

The plaintiff, Larissa Marland, individually and as administratrix of the estate of Norman Marland, filed a medical malpractice claim against the University of Connecticut Health Center and related entities. The decedent had been treated at the hospital and was later admitted to the intensive care unit, where he fell and subsequently died. The plaintiff alleged that the hospital staff breached the standard of care owed to the decedent.The plaintiff filed a notice of claim with the claims commissioner, including a physician’s opinion letter. The claims commissioner failed to resolve the claim within the statutory two-year period and an additional one-year extension granted by the General Assembly. Despite this, the commissioner eventually authorized the plaintiff to sue the state. The plaintiff then filed the present action in the Superior Court.The state moved to dismiss the complaint, arguing that the claims commissioner’s waiver of sovereign immunity was invalid because it was issued after the expiration of the one-year extension. The trial court agreed and dismissed the case for lack of subject matter jurisdiction, concluding that the commissioner did not have the authority to grant the waiver beyond the extension period.The Supreme Court of Connecticut reviewed the case and concluded that the trial court improperly dismissed the plaintiff’s action. The court held that, once the claims commissioner authorizes suit and waives sovereign immunity, the state cannot challenge that decision in the Superior Court. The court emphasized that such challenges should be raised before the claims commissioner. The court reversed the trial court’s judgment and remanded the case with direction to deny the state’s motion to dismiss. View "Marland v. University of Connecticut Health Center" on Justia Law

The defendant was convicted of three counts of sexual assault in the first degree. He appealed, arguing that the second count in the state's February 2020 substitute information was time-barred by the five-year statute of limitations. This count alleged conduct from January 1, 2014, which was first included in the 2020 substitute information, more than five years after the alleged conduct occurred.The trial court denied the defendant's motion to dismiss, reasoning that the defendant had notice of the 2014 allegations from the arrest warrant affidavit filed in 2018. The Appellate Court affirmed the trial court's decision, agreeing that the arrest warrant affidavit provided sufficient notice of the 2014 conduct, and thus, the 2020 substitute information did not substantially broaden or amend the timely charges.The Supreme Court of Connecticut reviewed the case and concluded that the arrest warrant affidavit does not toll the statute of limitations for uncharged conduct. The court held that the timely filed 2018 informations did not mention the 2014 conduct, and the defendant did not receive notice within the limitation period that he would be called to defend against the 2014 conduct. Therefore, count two of the 2020 substitute information substantially broadened or amended the timely charges and was time-barred under the statute of limitations.The Supreme Court reversed the Appellate Court's judgment regarding count two, directing the trial court to render a judgment of acquittal on that count and to resentence the defendant on the remaining counts. The judgment was affirmed in all other respects. View "State v. Orane C." on Justia Law

The plaintiff sought to register as a write-in candidate for the United States representative for the Third Congressional District of Connecticut in the November 2024 election. She claimed her registration was untimely due to following outdated guidance from the defendant, the Secretary of the State, which quoted an old version of the statute governing write-in candidacies. The plaintiff requested an order directing the defendant to accept her registration.The Superior Court previously dismissed the plaintiff's attempts to obtain relief for lack of jurisdiction. The plaintiff then brought this action under General Statutes § 9-323, seeking an emergency hearing to challenge the defendant's decision.The Connecticut Supreme Court held that the case was not moot despite being heard after election day, as practical relief was still available. The court found that the plaintiff was aggrieved by the defendant's ruling, as the untimely filing was allegedly due to erroneous information provided by the defendant's office.Assuming without deciding that courts have the authority to excuse noncompliance with mandatory filing deadlines due to election official actions, the court concluded that the plaintiff was not entitled to relief under the doctrine of equitable estoppel. The court noted that the correct deadline was clearly stated in both the cover letter and the registration form, and the plaintiff failed to exercise due diligence in resolving the apparent discrepancy.The court denied the plaintiff's request for an injunction and rendered judgment for the defendant, holding that the plaintiff's lack of due diligence did not warrant equitable relief from the mandatory statutory deadline. View "Whitnum Baker v. Secretary of the State" on Justia Law

The defendant was charged with multiple offenses related to a series of robberies and burglaries in 2020. He was incarcerated following his arrest in October 2020. During pretrial proceedings, the defendant reached a plea agreement with the state, which included a total effective sentence of ten years of imprisonment followed by five years of special parole. The sentences were to run concurrently and be stayed until April 1, 2022, to ensure that the defendant's pretrial credit was not affected.The defendant pleaded guilty in multiple judicial districts, and the courts issued sentences in accordance with the plea agreement. However, the defendant later filed a motion to correct an illegal sentence, arguing that he was promised 521 days of presentence confinement credit, but the commissioner of correction applied fewer days, resulting in a longer effective sentence.The trial court in the judicial district of New Britain dismissed the defendant's motion for lack of subject matter jurisdiction, citing the Appellate Court's decision in State v. Hurdle, which held that trial courts lacked authority under General Statutes § 18-98d to award presentence confinement credit.The Supreme Court of Connecticut reviewed the case and concluded that trial courts do have the authority to direct the commissioner to apply specific presentence confinement credit to a sentence on a judgment mittimus, as established in the companion case of State v. Hurdle. The court also determined that the defendant's motion raised a colorable claim that the plea agreement required the application of 521 days of presentence confinement credit and that there was no indication the defendant waived his statutory right to this credit.The Supreme Court of Connecticut reversed the trial court's judgment and remanded the case for further proceedings to consider the merits of the defendant's motion to correct an illegal sentence. View "State v. Nixon" on Justia Law

The defendant was charged with violating a protective order and was sentenced to five years of incarceration, execution suspended, followed by five years of probation. Later, he was arrested for threatening and subsequently charged with violating his probation. Due to COVID-19 related delays, the violation of probation arrest warrant was not served until several months after it was issued. The defendant remained in custody for several months before being released on bond. The trial court found the defendant in violation of his probation, revoked his probation, and sentenced him to five years of incarceration, execution suspended after six months, followed by three years and 250 days of probation.The trial court declined the defendant's request to direct the commissioner of correction to apply specific presentence confinement credit to his sentence, stating that the determination of such credits was within the purview of the Department of Correction. The defendant appealed this decision to the Appellate Court, which affirmed the trial court's judgment, relying on its decision in State v. Hurdle, which held that trial courts lack authority to award presentence confinement credit under General Statutes § 18-98d.The Supreme Court of Connecticut reviewed the case and concluded that trial courts do have the authority to direct the commissioner to apply specific presentence confinement credit to a sentence on a judgment mittimus, as established in the companion case of State v. Hurdle. The court disagreed with the state's argument that the defendant was not entitled to credit starting from the date the arrest warrant was signed, noting that the defendant was not serving another sentence during that time. The Supreme Court reversed the Appellate Court's judgment in part and remanded the case to the trial court to exercise its discretion in accordance with this opinion. View "State v. Eric L." on Justia Law

The defendant was convicted of robbery in the first degree and conspiracy to commit robbery in the first degree following a guilty plea. He appealed, claiming that the trial court incorrectly concluded it lacked authority to direct the commissioner of correction to apply presentence confinement credit to his sentence. The defendant also argued that his plea agreement included an understanding that he would receive such credit and that there was no meeting of the minds on this issue, rendering the plea agreement void.The trial court had denied the defendant’s request for presentence confinement credit, stating it had no discretion under the statute to grant it. The court also denied the defendant’s motion to withdraw his guilty pleas, finding no reason to believe he did not understand the terms of the plea agreement. The Appellate Court affirmed the trial court’s judgment, concluding that the trial court lacked authority to award presentence confinement credit and that the plea agreement did not include an agreement for such credit.The Supreme Court of Connecticut reviewed the case and concluded that the trial court does have discretionary authority under the statute to direct the commissioner to apply specific presentence confinement dates to a sentence. The court found that the legislative history and statutory text support the trial court’s inherent authority to issue such orders. The court reversed the Appellate Court’s judgment regarding the trial court’s authority to order presentence confinement credit and remanded the case for the trial court to exercise its discretion on this issue.The Supreme Court also agreed with the Appellate Court that the plea agreement did not include an agreement for presentence confinement credit and that the defendant’s subjective belief that he would receive such credit was unreasonable. The court affirmed the Appellate Court’s judgment in all other respects. View "State v. Hurdle" on Justia Law