Justia Connecticut Supreme Court Opinion Summaries

In this public interest appeal, the Supreme Court affirmed the order of the trial court certifying a class action of servers employed by Chip's Family Restaurant, holding that the trial court did not err or abuse its discretion.Plaintiff alleged in her class action complaint that Defendants had violated Connecticut wage laws and regulations by deducting a tip credit from her earnings and paying her and other class members below minimum wage for the performance of "nonservice" tasks in connection with their duties as servers. After class discovery, Plaintiff moved for class certification. The trial court granted the motion. The Supreme Court affirmed, holding that the trial court did not abuse its discretion in certifying this class action. View "Rodriguez v. Kaiaffa, LLC" on Justia Law

The Supreme Court affirmed the judgment of the Appellate Court affirming the trial court's judgment of possession rendered in favor of Plaintiffs, holding that the trial court properly rejected Defendants' claim that the doctrine of equitable nonforfeiture should have operated to prevent their eviction in a summary process action for nonpayment of rent under the terms of a commercial lease.After Defendants failed to pay rent, Plaintiffs served a notice to quit on Defendants, thereby terminating the parties' lease. Because Defendants did not subsequently vacate the premises Plaintiffs initiated this summary process action. In response, Defendants raised special defenses, including the special defense of equitable nonforfeiture. The trial court rendered judgment of possession for Plaintiffs. The Appellate Court affirmed. The Supreme Court affirmed, holding that the trial court did not abuse its discretion in refusing to grant Defendants equitable relief from forfeiture and granting possession of the premises to Plaintiffs. View "Boccanfuso v. Daghoghi" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of two counts of sexual assault in the first degree and one count of criminal attempt to commit sexual assault in the first degree, holding that there was no error.Specifically, the Supreme Court held (1) the trial court did not violate Defendant's right to confrontation by allowing testimony about the results of a DNA identification analysis without requiring testimony from the individual who generated the DNA profiles; (2) Defendant's claim that his due process rights were violated by the introduction of DNA identification evidence that was allegedly unreliable failed under the third prong of State v. Golding, 567 A.2d 823 (Conn. 1989); and (3) there was sufficient evidence to establish Defendant's guilt beyond a reasonable doubt. View "State v. Rodriguez" on Justia Law

The Supreme Court reversed in part the judgment of the trial court granting Plaintiff's motion to vacate an arbitration award and denying Defendant's corresponding application to confirm the award, holding that the arbitrator did not exceed her authority or manifestly disregard the law, but the inclusion of issues related to child support in the award was improper.Before the parties were married they executed a premarital agreement. Years later, Plaintiff brought this action to dissolve the marriage, and the parties executed a binding agreement to arbitrate the dissolution action. At issue was the validity of the arbitrator's award dividing the equity in the parties' marital home and assigning responsibility for certain expenses related to child support. The trial court granted Plaintiff's motion to vacate the portion of the arbitration award. The Supreme Court reversed in part, holding (1) the trial court erred in ruling that the arbitrator's award exceed the scope of the parties' submission; (2) any error in distributing the equity in the marital home would not permit a court to vacate the arbitration award; and (3) because Connecticut law prohibits the inclusion of issues related to child support in arbitration awards, this portion of the award is reversed. View "Blondeau v. Baltierra" on Justia Law

The Supreme Court affirmed the judgment of the Appellate Court affirming Defendant's conviction, holding that Defendant's conviction of two counts of violating a standing criminal protective order did not violate Defendant's right against double jeopardy and that any possible instructional error in the trial court's definition of "harassing" was harmless.Defendant was convicted of two counts of criminal violation of a standing protective order, one count of threatening in the second degree, and one count of threatening in the second degree. The convictions arose from a series of statements Defendant made to the person protected by the order during a court hearing. The Supreme Court affirmed, holding (1) Defendant's two convictions for violation of a standing criminal protective order did not violate the constitutional protection against double jeopardy; and (2) even if this Court were to assume that Defendant's allegations of instructional error were valid, any impropriety was harmless. View "State v. Cody M." on Justia Law

The Supreme Court affirmed the judgment of the Appellate Court affirming Defendant's judgment of conviction for criminal trespass in the first degree, holding that that the Appellate Court correctly concluded that the prerequisites set forth in State v. Whistnant, 427 A.2d 414 (1980), for obtaining a jury instruction on a lesser included offense were not satisfied in this case.On appeal, Defendant argued that the trial court should have instructed the jury on the infraction of simple trespass as a lesser included offense. The Appellate Court disagreed, concluding that the requested instruction failed the third and fourth elements of Whistnant. The Supreme Court agreed, holding that the Appellate Court did not err in concluding that the trial court properly declined to instruct the jury on the infraction of simple trespass. View "State v. Marsala" on Justia Law

In this appeal requiring the Supreme Court to determine the priority of tax liens levied on real property by the Georgetown Special Taxing District the Supreme Court reversed the judgment of the trial court subordinating liens acquired by Defendant to the Georgetown Fire District, holding that the fire district's tax liens were subordinate to those of Defendant, which, in turn, were subordinate to those of the town.Plaintiffs - the town of Redding, the Redding Water Pollution Control Commission, and Georgetown Fire District - brought this action to foreclose municipal liens against Defendant RJ Tax Lien Investments, LLC, who had been assigned real estate tax liens originally levied by the taxing district. The trial court granted the motions for partial summary judgment with respect to priority filed by the town and the fire district and rendered a judgment of strict foreclosure in favor of the town and the fire district. The Supreme Court reversed in part, holding that the trial court incorrectly concluded that Defendant's liens were subordinate to those of the fire district. View "Redding v. Georgetown Land Development Co., LLC" on Justia Law

The Supreme Court affirmed the judgment of the trial court rendered in favor of Defendants on Plaintiffs' medical monitoring claims stemming from a workplace asbestos exposure at Sikorsky Aircraft Corporation's cogeneration project in Stratford, holding that the trial court properly granted Defendants' motion for summary judgment.The named plaintiff brought a class action complaint against Sikorsky and Carrier Corporation, alleging negligence, battery, recklessness, and strict liability for violations of the federal Clean Air Act, 42 U.S.C. 7401 et seq. and seeking remedies for asbestos exposure while working at the Sikorsky cogeneration project. The trial court granted Defendants' motion for summary judgment. In so doing, the court declined to recognize a cause of action for medical monitoring under Connecticut law that would allow recovery for an increased risk of future injury rather than a present injury. The Supreme Court affirmed, holding that, even if this Court were to recognize a medical monitoring claim in the absence of any physical manifestation of injury under Connecticut law, Plaintiffs nevertheless failed to establish a genuine issue of material fact as to certain elements of the claim. View "Dougan v. Sikorsky Aircraft Corp." on Justia Law

In this insurance dispute, the Supreme Court reversed the judgment of the trial court granting Defendant's motion for summary judgment, holding that the trial court incorrectly determined that Defendant was relieved of its duty to defend in the underlying property dispute.Plaintiff contracted with New Beginnings Residential Renovations, LLC to renovate Plaintiff's house. The house received extensive physical damage during the renovation, and Plaintiff brought an action against New Beginnings for property damage. New Beginnings tendered defense of the case to Defendant pursuant to a commercial general liability insurance policy. Defendant declined to defend under two of the policy's "business risk" exclusions. Plaintiff was awarded a default judgment against New Beginnings. Plaintiff then brought this action against Defendant under the direct action statute seeking recovery for the judgment against New Beginnings. The trial court granted summary judgment for Defendant, concluding that the policy exclusions precluded coverage. The Supreme Court reversed and remanded the case, holding that the exclusions did not relieve Defendant of its duty to defend. View "Nash Street, LLC v. Main Street America Assurance Co." on Justia Law

The Supreme Court reversed the trial court's judgment determining Defendant's method of calculating a supplemental sewerage benefit assessment levied against certain of Plaintiff's real property, holding that the trial court incorrectly determined that Conn. Gen. Stat. 7-249 required Defendant to use the same method to calculate the supplemental assessment as was used to calculate the initial assessment.At issue was whether Defendant had authority to levy a supplemental assessment against Plaintiff's property and, if so, whether it used the correct methodology in calculating that assessment. A predecessor of Defendant levied a sewerage benefit assessment against the owners of the property. Later, the building was demolished and a new commercial office building was constructed in its place. No supplemental assessment was levied as a result of the construction. Plaintiff later purchased the property and converted it into a residential condominium community. Defendant then levied a supplemental assessment on the property. The trial court concluded that Defendant's supplemental assessment calculation violated section 7-249 because it should have been calculated on the basis of street frontage, as was the initial assessment. The Supreme Court reversed in part, holding (1) Defendant had authority to levy the supplemental assessment; and (2) the trial court erred in determining that Defendant incorrectly calculated the supplemental assessment. View "777 Residential, LLC v. Metropolitan District Commission" on Justia Law