Justia Connecticut Supreme Court Opinion Summaries

The Supreme Court reversed in part the judgment of the trial court ordering the disclosure of a redacted version of a police report created by the police department at the Whiting Forensic Division of Connecticut Valley Hospital documenting the police department's investigation into the death of a Whiting patient after a medical event, holding that the report, with minimal redaction, must be disclosed pursuant to the Freedom of Information Act (FOIA), Conn. Gen. Stat. 1-200 et seq.After the trial court ordered the disclosure of a redacted version of the police report the Freedom of Information Commission appealed, arguing that the report should be released in its entirety under FOIA because it was not exempt for disclosure by the psychiatrist-patient communications privilege set forth in Conn. Gen. Stat. 52-146d(2) and 52-146e(a), as well as the Health Insurance Portability and Accountability Act (HIPAA), 42 U.S.C. 1320d et seq., as implemented by the Privacy Rule, 45 C.F.R. 160.101 et seq. The Supreme Court reversed, holding (1) the police report was not a communication or record exempt from disclosure under FOIA; and (2) because the report included identifiable patient information, the report should be redacted in the manner described in this opinion. View "Comm'r of Mental Health & Addiction Services v. Freedom of Information Comm'n" on Justia Law

The Supreme Court affirmed the judgment of the appellate court affirming Defendant's conviction of risk of injury to a child, holding that Defendant was not entitled to relief on his allegations of error.On appeal, Defendant argued, among other things, that the trial court abused its discretion in precluding defense counsel from asking potential jurors about their views on parents kissing their children on their lips. The Supreme Court affirmed, holding (1) even if the trial court improperly limited defense counsel's questions to potential jurors, any error did not result in harmful prejudice; and (2) the trial court did not abuse its discretion by admitting into evidence a video recording of a forensic interview of the victim concerning the crimes at issue. View "State v. James K." on Justia Law

The Supreme Court affirmed the judgment of the appellate court concluding that No. 17-4, 1 of the 2017 Special Acts (S.A. 17-4) was an unconstitutional public emolument in violation of Conn. Const. Art. I, 1 because it did not serve a legitimate public purpose, holding that the appellate court did not err.The State brought this action seeking a judgment declaring that S.A. 17-4, pursuant to which the General Assembly extended the time limitation for Defendants to bring their action against the State for injuries arising from poor air quality at public schools, constituted an unconstitutional public emolument. The trial court granted summary judgment for the State. The appellate court affirmed. Defendants appealed, arguing that the appellate court failed to consider whether the State met its burden of proving that the General Assembly's "sole objective" in acting S.A. 17-4 was to grant a personal gain or advantage to Defendants. The Supreme Court affirmed, holding that S.A. 17-4 provided an exclusive, private benefit to Defendants that no other similarly situated litigant could enjoy, in violation of the public emoluments clause. View "State v. Avoletta" on Justia Law

The Supreme Court affirmed the judgment of the trial court denying the State's motion to dismiss the second count of the complaint filed by Celine Escobar-Santana (Celine) and her son Emmett Escobar-Santana (Emmett), holding that the phrase "medical malpractice claims" in Conn. Gen. Stat. 4-160(f) was broad enough to encompass Celine's claim for emotional distress damages under the circumstances of this case.Celine brought this action alleging that she suffered emotional distress damages from physical injuries to Emmett that were proximately caused by the negligence of health care professionals (collectively, Defendants) during the birthing process. The State moved to dismiss count two of the complaint on the ground that the count did not fall within the statutory waiver of the State's sovereign immunity in section 4-160(f) because the count stated a claim for negligent infliction of emotional distress or bystander liability rather than medical malpractice. The trial court denied the motion. The Supreme Court affirmed, holding that Celine's allegation that she suffered a traumatic delivery followed by severe psychological distress was inextricably connected to her allegations of medical malpractice and therefore qualified as a medical malpractice claim for purposes of section 4-160(f). View "Escobar-Santana v. State" on Justia Law

In this case determining the scope of immunity afforded by Executive Order No. 7V, as it related to acts or omissions undertaken in good faith by health care professionals and health care facilities because of an alleged lack of resources attributable to the COVID-19 pandemic the Supreme Court upheld the judgment of the trial court concluding that Defendants failed to establish that the immunity afforded by the order applied in this case.Governor Ned Lamont issued Executive Order No. 7V providing immunity from suit and liability to health care providers under certain circumstances relating to COVID-19. Plaintiff in this case filed wrongful death claims against Defendants, Regency House of Walling ford, Inc. and National Health Care Associates, Inc., alleging twelve counts of wrongful death based on medical negligence and medical recklessness. Defendants moved to dismiss the complaint, claiming immunity under Executive Order No. 7V. The trial court denied the motion to dismiss. The Supreme Court affirmed, holding that the trial court too narrowly construed the language of the order but nevertheless did not err in denying Defendants' motion to dismiss. View "Manginelli v. Regency House of Wallingford, Inc." on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the trial court in his wrongful death action filed by the daughter of the decedent and the executor of her estate, holding that the trial court erred in dismissing counts five, six, and seven of the complaint.At issue was Executive Order No. 7V, which conferred immunity on health care providers in connection with the governor's March, 2020 declaration of a public health emergency caused by the COVID-19 pandemic. Plaintiff brought this action against several physicians and a hospital, but Defendants moved to dismiss the complaint on the ground that they were immune under the federal Public Readiness and Emergency Preparedness Act (PREP Act) for allegedly grossly negligent acts and omissions undertaken before the receipt of the decedent's negative COVID-19 test result. The court granted the motions to dismiss as to certain physicians. The Supreme Court affirmed in part and reversed in part and remanded the case for further proceedings, holding that the trial court erred in concluding that Defendants were entitled to immunity under the PREP Act. View "Mills v. Hartford HealthCare Corp." on Justia Law

The Supreme Court affirmed the judgment of the trial court dismissing Plaintiff's action for a writ of mandamus ordering Defendant, the chief court reporter for the judicial district of Stamford-Norwalk, to produce transcripts that were sealed by another trial court in a separate proceeding involving unrelated parties, holding that the trial court correctly determined that Plaintiff's action was nonjusticiable.Jennifer Dulos commenced a marital dissolution against Fotis Dulos. Following a hearing relating to the custody of the parties' children the family court closed the courtroom to the public and sealed the hearing transcripts. Fotis subsequently died, and the family court dismissed the martial dissolution action. Plaintiff then commenced this action seeking an injunction compelling Defendant to produce the transcripts. Defendant filed a motion to dismiss, arguing that to grant the requested relief would require the trial court to overturn the order sealing the transcripts. The trial court dismissed the action for lack of subject matter jurisdiction. The Supreme Court affirmed, holding that Plaintiff's complaint did not present a justiciable claim. View "Schoenhorn v. Moss" on Justia Law

In this action to foreclose on a mortgage on Defendant's real property, the Supreme Court reversed the judgment of the appellate court upholding the decision of the trial court to grant a motion for a protective order regarding the production of MTGLQ Investors, L.P.'s mortgage file, holding that the trial court erred in granting the protective order.Defendant executed a promissory note that was secured by a mortgage deed on Defendant's residential property. JPMorgan Chase Bank filed the present foreclosure action alleging that Defendant was in default. MTGLQ was subsequently substituted for JPMorgan. When Defendant sought production of MTGLQ's mortgage file relating to the mortgage note and deed at issue in this case and other documents MTGLP moved for a protective order, which the trial court granted to prevent the improper use of discovery. The trial court rendered judgment of foreclosure by sale in favor of MTGLQ. The appellate court affirmed. The Supreme Court reversed, holding that the trial court abused its discretion in granting MTGLQ's motion for a protective order, and Defendant established that he was harmed by the granting of the motion for a protective order. View "JPMorgan Chase Bank, Nat'l Ass'n v. Lakner" on Justia Law

The Supreme Court reversed the judgment of the habeas court granting Petitioner's petition for a writ of habeas corpus, holding that the habeas court erred when it determined that trial counsel for Petitioner rendered deficient performance under Strickland v. Washington, 466 U.S. 668 (1984).Petitioner was convicted of murder and sentenced to sixty-years' imprisonment. Petitioner later brought his habeas petition, claiming ineffective assistance of trial counsel. The habeas court determined that trial counsel rendered ineffective assistance by failing to recommend that Petitioner accept the court's pretrial offer of a forty-five-year sentence of incarceration. The Supreme Court reversed, holding that, under the circumstances of this case, counsel's representation of Petitioner did not amount to ineffective representation. View "Maia v. Commissioner of Correction" on Justia Law

The Supreme Court reversed the judgment of the trial court in favor of the Town of Bloomfield, the Bloomfield Police Department, and one of its police officers, in this personal injury action, holding that the defense of discretionary act immunity provided by Conn. Gen. Stat. 52-557n(a)(2)(B) does not apply to claims arising from the manner in which an emergency vehicle is operated under the privileges provided by Conn. Gen. Stat. 14-283.Plaintiff and her children sustained personal injuries when police officer Jonathan Sykes collided with the driver's side of Plaintiff's vehicle. Plaintiff brought this action claiming negligence, negligent supervision, and respondent superior. Defendants moved for summary judgment on the grounds that the claims were barred by discretionary act immunity under section 52-557n(a)(2)(B). The Supreme Court reversed, holding that the discretionary act immunity provided by § 52-557n(a)(2)(B) does not apply to the manner in which an emergency vehicle is operated by virtue of the codified, common-law duty to drive with "due regard" pursuant to section 14-283(d). View "Adesokan v. Bloomfield" on Justia Law