Justia Connecticut Supreme Court Opinion Summaries

The Supreme Court affirmed in part and reversed in part the judgment of the Appellate Court affirming Defendant's conviction of two counts of assault in the first degree as a principal and two counts of assault in the first degree as an accessory, holding that the Appellate Court erred insofar as it affirmed Defendant's assault conviction as to Kenneth Tucker.Defendant's convictions were based on a joint physical assault involving two perpetrators, Defendant and his brother, and two victims, Kenneth Tucker and Luis Rodriguez. On appeal, Defendant argued that his conviction of four assault violated his right to be free from double jeopardy under the federal constitution because he committed only one assault per victim, for a total of two assaults. The Supreme Court reversed the Appellate Court's judgment insofar as it affirmed Defendant's conviction as to Tucker, holding (1) the imposition of multiple punishments on Defendant for Tucker's assault violated the Double Jeopardy Clause; and (2) Defendant's criminal acts involving Rodriguez constituted two distinct courses of conduct for double jeopardy purposes. View "State v. Ruiz-Pacheco" on Justia Law

The Supreme Court reversed the conclusion of the trial court that Plaintiff, E. I. du Pont de Nemours & Co., had not strictly complied with the notice provisions of an asset purchase agreement (APA) and the court's judgment in favor of Defendant, Chemtura Corporation, holding that the trial court improperly required strict compliance with the APA's notice provisions.On appeal, Plaintiff argued that the trial court incorrectly concluded that New York law requires strict compliance with a notice provision in a commercial contract. Specifically, Plaintiff asserted that New York law distinguishes between public contracts and private commercial contracts and does not require strict compliance in commercial contracts if the contracting party receives actual notice and suffers from prejudice. The Court of Appeals agreed, holding that the trial court erred in requiring strict compliance with the APA's notice provision and in failing to make any other factual findings regarding Plaintiff's breach of contract claims. View "E. I. du Pont de Nemours & Co. v. Chemtura Corp." on Justia Law

The Supreme Court reversed the judgment of the Appellate Court affirming the judgment of the habeas court denying Petitioner's second petition for a writ of habeas corpus, holding that Petitioner's federal due process rights were violated when the State knowingly failed to correct the false testimony of two prosecution witnesses when defense counsel was aware of the falsity of the testimony.A jury found Petitioner and his codefendants guilty of murder and conspiracy to commit murder. In his second petition for a writ of habeas corpus Petitioner alleged that his prior habeas counsel provided ineffective assistance in that he failed to raise the claim that the State had violated Petitioner's right to due process by failing to correct the allegedly false testimony of two witnesses at trial. The habeas court denied the petition, and the Appellate Court affirmed. The Supreme Court reversed, holding that, in light of the facts of this case, the fact that counsel was aware of the falsity of the testimony was insufficient to protect Petitioner's due process rights. View "Gomez v. Commissioner of Correction" on Justia Law

In this case stemming from a fatal automobile accident arising from a high-speed police pursuit, the Supreme Court affirmed the order of the trial court granting summary judgment in favor of a town and its municipal officers, holding that the trial court correctly concluded that Defendants were shielded by governmental and qualified immunity from liability for the decision to pursue the fleeing motorist.The decedent, a passenger in the vehicle that was pursued by police officers, was killed when the vehicle struck an embankment and turned over onto its roof. Plaintiff brought this action alleging that the police officers were negligent in pursuing the vehicle and that the town was liable for the negligent acts of its agents and employees. The trial court concluded that the officers' alleged actions involved the exercise of discretion and that an exception to discretionary act immunity did not apply. The Supreme Court affirmed, holding (1) Conn. Gen. Stat. 14-283(d) imposes a discretionary duty on police officers to give due regard to the safety of all persons and property when determining whether to engage a pursuit; and (2) the trial court did not err in concluding that the identifiable person-imminent harm exception to governmental immunity did not apply in the present case. View "Borelli v. Renaldi" on Justia Law

The Supreme Court reversed the order of the district court denying Father's motion to dismiss a petition to adjudicate a newborn child neglected on the basis of "predictive neglect" when the parents relocated to another state before the child's birth, holding that the Connecticut trial court lacked subject matter jurisdiction.After the Commissioner of Children and Families filed a petition seeking to terminate Respondents' parental rights, Respondents drove to Florida and signed a one-year lease for an apartment. Two days after the child's birth, the Florida Department of Children and Families took custody of the child. The Connecticut trial court then filed a petition seeking to adjudicate the child neglected. The motion was denied on the ground that the child was not in Connecticut. Thereafter, the Florida department filed a motion to transfer jurisdiction to the Connecticut trial court, which the magistrate granted. Thereafter, Father filed a motion to dismiss the pending neglect petition on the ground of lack of subject matter jurisdiction. The Connecticut trial court denied Father's motion. The Supreme Court reversed, holding that a Connecticut trial court could not exercise subject matter jurisdiction over the neglect petition because any neglect of the child would never occur in Connecticut. View "In re Teagan K.-O." on Justia Law

The Supreme Court affirmed the judgment of the Appellate Court affirming Defendant's conviction of breach of the peace in the second degree, criminal mischief in the third degree, and threatening in the second degree, holding that there was no error.On appeal, Defendant argued that the Appellate Court erred in determining that the trial court did not abuse its discretion by precluding Defendant from cross-examining the state's key witness about the facts underlying the witness's prior misdemeanor convictions. The Supreme Court disagreed, holding (1) the facts underlying the witness's prior misdemeanor conviction were not relevant to veracity, motive, intent, or a common scheme or pattern; and (2) therefore, the trial court did not abuse its discretion by precluding this evidence. View "State v. Rivera" on Justia Law

The Supreme Court affirmed the judgment of the Appellate Court granting in part Plaintiffs' motion to dismiss Defendants' appeal from the judgment of the trial court rendered following a jury verdict in favor of Plaintiffs on certain medical malpractice claims and denied Defendants' motion to suspend the rules of practice to permit a late appeal, holding that the Appellate Court did not err.On appeal, Defendants argued that the Appellate Court erred in granting Plaintiffs' motion to dismiss the portion of the appeal challenging the jury's verdict as untimely and abused its discretion in denying their motion to suspend the rules of practice to permit a later appeal. The Supreme Court affirmed, holding (1) the Appellate Court correctly concluded that the appeal was untimely; and (2) the Appellate Court did not abuse its discretion or work injustice by determining that Defendants had failed to establish good cause for their failure to file a timely appeal. View "Georges v. OB-GYN Services, P.C." on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the trial court sustaining in part and dismissing in part Lime Rock Park, LLC's appeal from the adoption of the Planning Zoning Commission of the Town of Salisbury of certain amendments to the Town's zoning regulations restricting motor vehicle racing activities on property owned by Lime Rock, holding that the trial court erred in part.Specifically, the Supreme Court held (1) the trial court erred when it (a) sustained the portion of Plaintiff's appeal claiming that the provision of the regulations prohibiting racing activities on Sundays was statutorily preempted, (b) denied the portion of the appeal claiming that the Commission lacked the authority to condition the filing of a petition to amend the regulations on obtaining a special permit, and (c) concluded that the amended regulation prohibited racing activities on Saturdays; and (2) the trial court did not err when it denied the portion of the appeal claiming that the restrictions on unmufflered racing are subject to the provision of Conn. Gen. Stat. 22a-73(c) requiring the Commissioner of Energy and Environmental Protection to approve municipal noise control ordinances. View "Lime Rock Park, LLC v. Planning & Zoning Commission" on Justia Law

The Supreme Court affirmed the judgment of the trial court in favor of Defendants, Boehringer Ingelheim Pharmaceuticals, Inc. and Boehringer Ingelheim International, GmbH, on claims brought by Plaintiff, the executrix of the decedent's estate, that an oral anticoagulant medication wrongfully caused the decedent's death, holding that the trial court did not err.Specifically, the Supreme Court held that the trial court did not improperly (1) preclude evidence and arguments related to spoliation; (2) prevent Plaintiff from using an excerpt from a particular deposition on rebuttal; (3) grant Defendants' motion for summary judgment on a design defect claim relating to the absence of a reversal agent; and (4) issue a curative instruction to the jury after closing arguments. View "Boone v. Boehringer Ingelheim Pharmaceuticals, Inc." on Justia Law

The Supreme Court reversed the order of the Appellate Court summarily dismissing Defendants' appeal challenging the priority of Plaintiff's mortgage over Defendants' mortgage for want of a final judgment, holding that a determination of the priority of mortgages can be challenged in an appeal from the judgment of foreclosure by sale, before the foreclosure sale has taken place, when the priority of the foreclosing plaintiff's mortgage is in dispute.Plaintiff sought a judgment of foreclosure on certain real property and a declaratory judgment that his mortgage had priority over an alleged mortgage on the property held by Defendants. The Appellate Court dismissed the appeal for want of a final judgment. The Supreme Court reversed, holding that the judgment of foreclosure by sale was a final judgment that manifestly met the requirements of Practice Book 61-2. View "Saunders v. KDFBS, LLC" on Justia Law