Justia Connecticut Supreme Court Opinion Summaries

The Supreme Court held that Conn. Gen. Stat. 28-9 provided authority for Governor Ned Lamont to issue executive orders during the civil preparedness emergency he declared pursuant to the statute in response to the COVID-19 pandemic and that the statute passes constitutional muster.In response to the pandemic, Governor Lamont issued certain executive orders that limited various commercial activities at the State's bars and restaurants. At issue in this case was whether the COVID-19 pandemic constituted a "serious disaster" pursuant to section 28-9 and whether that statute conferred authority on the governor to issue the challenged executive orders. The Supreme Court held (1) Governor Lamont did not exceed his statutory authority when he issued the challenged orders; and (2) section 28-9 is not an unconstitutional delegation of the General Assembly's legislative powers to the governor. View "Casey v. Lamont" on Justia Law

The Supreme Court affirmed the judgment of the appellate court affirming Defendant's conviction of murder as either a principal or as an accessory, holding that Defendant was not entitled to relief on any of his allegations of error.On appeal, Defendant argued that the appellate court abused its discretion by denying him permission to file a supplemental brief to raise a new claim pursuant to Carpenter v. United States, __ U.S. __ (2018) and incorrectly determined that his hearsay claim regarding the testimony of a key state witness was unpreserved. The Supreme Court affirmed, holding (1) the appellate court should have granted Defendant's motion to file a supplemental brief, but any error was harmless; and (2) the trial court properly admitted the challenged testimony as nonhearsay and, alternatively, any error was harmless. View "State v. Armadore" on Justia Law

The Supreme Court reversed the sentence imposed upon Defendant in connection with his conviction of four counts of sexual assault in the first degree and three counts of risk of injury to a child, holding that the trial court improperly sentenced Defendant to a period of probation on each count of sexual assault, in violation of Conn. Gen. Stat. 53a-29(a).After a jury trial, Defendant was found guilty of sexually abusing his daughter. The trial court sentenced Defendant to twenty-five years of imprisonment, execution suspended after twenty years, and ten years of probation on each count of sexual assault and ten years of imprisonment on each count of risk of injury to a child. The sentences were imposed concurrently. The Supreme Court affirmed the convictions but reversed the sentence, holding (1) the trial court improperly imposed a period of probation on each of Defendant's four sexual assault convictions; and (2) Defendant's challenges to his conviction failed. View "State v. Jose R." on Justia Law

The Supreme Court affirmed the judgment of the trial court denying Defendant's motion to set aside the jury's verdict in this breach of contract action on the grounds that the terms of the underlying contract precluded such relief, holding that there was no error.Plaintiff, a general contractor, entered into a contract with Defendant, a subcontractor, to provide services related to the installation of drywall and trim. Plaintiff later filed this action alleging that Defendant breached the contract by abandoning performance. The jury found Defendant liable and awarded Plaintiff $45,374. Defendant appealed, arguing that the trial court committed reversible error by declining to set aside the jury's award. The Supreme Court affirmed, holding that Defendant failed to meet its burden of demonstrating that the jury could not have reasonably reached the verdict that it did. View "Viking Construction, Inc. v. TMP Construction Group, LLC" on Justia Law

The Supreme Court affirmed the judgment of the appellate court dismissing Petitioner's appeal from the judgment of the habeas court denying Petitioner's petition for a writ of habeas corpus, holding that Petitioner could not prevail on his claim of ineffective assistance of trial counsel.Petitioner was convicted of robbery in the first degree. Later, Petitioner filed a petition for a writ of habeas corpus, asserting that he had received ineffective assistance of counsel during plea negotiations prior to his trial. The appellate court dismissed the petition. The Supreme Court affirmed, holding that Petitioner failed to meet his burden of proving that his attorney did not adequately advise him of his maximum sentencing exposure if convicted of the lesser included offense of robbery in the third degree. View "Moore v. Commissioner of Correction" on Justia Law

The Supreme Court affirmed the judgment of the appellate court affirming the decision of the trial court dismissing Plaintiff's declaratory judgment action for lack of subject matter jurisdiction, holding that the appellate court properly upheld the trial court's dismissal of the action as not ripe.Plaintiff, who was convicted of murder, has been incarcerated since 1990. Plaintiff brought this action seeking a judgment declaring that Conn. Gen. Stat. 54-125g was applicable to him and that the commissioner must factor his eligibility for early release in his time sheet. The trial court concluded that the issue raised by Plaintiff was not ripe. The appellate court affirmed. The Supreme Court affirmed, holding that Plaintiff's claims were nonjusticiable and that the trial court lacked subject matter jurisdiction on this alternative ground. View "Francis v. Board of Pardons & Paroles" on Justia Law

The Supreme Court affirmed the judgment of the appellate court reversing the judgment of the trial court and concluding that Plaintiffs, the city of Meriden and the Meriden City Council, did not violate the open meeting requirements of the Freedom of Information Act, Conn. Gen. Stat. 1-200 et seq., holding that there was no error.At issue on appeal was whether the appellate court correctly determined that the phrase a "hearing or other proceeding of a public agency" contained in section 1-200(2) refers to a process of adjudication that fell outside the scope of the activities conducting during the gathering at issue. The Supreme Court affirmed, holding (1) the subject gathering did not constitute a "hearing or other proceeding of a public agency" and therefore a "meeting"; and (2) consequently, the gathering was not subject to the Act's open meeting requirements. View "Meriden v. Freedom of Information Commission" on Justia Law

The Supreme Court affirmed the judgment of the appellate court affirming Defendant's conviction of strangulation in the second degree and assault in the third degree, holding that there was no error in the trial court's evidentiary rulings and that there was no reason to mandate Defendant's requested jury instruction.Defendant was convicted of strangulation in the second degree and assault in the third degree. The appellate court affirmed the convictions. The Supreme Court affirmed, holding (1) the appellate court did not err in upholding the trial court's decision to admit into evidence a written statement that Defendant made during a custodial interrogation; and (2) this Court declines Defendant's request to exercise its supervisory authority to require trial court, in cases in which the police fail to record an interrogation in violation of Conn. Gen. Stat. 54-lo(h), to instruct the jury that the police violated the law. View "State v. Christopher S." on Justia Law

The Supreme Court reversed the judgment of the trial court in favor of Plaintiffs on all counts in this commercial dispute, holding that the trial court failed properly to instruct the jury regarding the legal effects of the parties' contract in this case and the proper means of calculating damages.Plaintiffs brought this action alleging promissory estoppel, negligent misrepresentation, tortious interference with business expectancies, and violations of the Connecticut Unfair Trade Practices Act (CUTPA), Con. Gen. Stat. 42-110a et seq., and seeking damages, injunctive relief, and attorney fees and costs. The jury returned a verdict for Plaintiffs on all counts. The Supreme Court reversed, holding (1) there was sufficient evidence for the jury to find Defendants liable; but (2) the trial court abused its discretion in issuing the injunction at issue, and the injunction was unenforceable. View "Kent Literary Club of Wesleyan University v. Wesleyan University" on Justia Law

The Supreme Court affirmed the judgment of the trial court granting the application of Defendant, AFSCME, Council 4, Local 344 (Union), to confirm an arbitration award reinstating Nichole Jefferson to her employment as executive director of the City of New Haven's Commission on Equal Opportunities, holding that the trial court did not err in determining that the award did not violate public policy.The Union filed a grievance, claiming that the City did not have just cause to terminate Jefferson. The arbitration panel reinstated Jefferson to her employment. Thereafter, the trial court issued an order granting the Union's application to confirm the award and denying the City's corresponding application to vacate, concluding that Jefferson's reinstatement did not violate public policy. The Supreme Court affirmed, holding that the City failed to meet its burden of demonstrating that Jefferson's reinstatement violated public policy. View "New Haven v. AFSCME, Council 4, Local 3144" on Justia Law