Justia Connecticut Supreme Court Opinion Summaries

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

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