Justia Connecticut Supreme Court Opinion Summaries

The Supreme Court reversed the judgments of the Appellate Court determining that it was required to apply State v. Hossan-Maxwell, Inc., 436 A.2d 284 (Conn. 1980), to this case, holding that Hossan-Maxwell, Inc. is overruled.Plaintiffs and Defendants entered into agreements for the sale of property. Defendants included list-back provisions in their purchase and sale agreements for two parcels. Plaintiffs later filed suit alleging breach of contract and anticipatory breach. Defendants raised several defenses, arguing, as relevant to this appeal, that the list-back provisions in the parties' purchase and sale agreements were illegal tying arrangements. The trial court ruled for Defendants. The Appellate Court affirmed on the basis of the antitrust defense. The Supreme Court reversed, holding (1) the trial court should not have found the list-back agreements unenforceable without first engaging in a full market analysis, as a per se ban on list-back agreements, as applied in Hossan-Maxwell, Inc. is inconsistent with federal antitrust law as it has evolved over the decades; and (2) the trial court's judgments cannot be affirmed under the proper legal standard. View "Reserve Realty, LLC v. Windemere Reserve, LLC" on Justia Law

The Supreme Court reversed the judgment of the Appellate Court affirming the trial court's dismissal of Petitioner's petition for a new trial brought against Respondent, the state's attorney, as time barred, holding that the Appellate Court improperly disregarded the remedial purpose of Conn. Stat. Ann. 52-593a in concluding that the successful fax transmission of process to the state marshal is not personal delivery as contemplated by the savings statute.Petitioner was convicted of murder and sentenced to forty-five years imprisonment. Petitioner subsequently sought to file a petition for a new trial on the basis of newly discovered evidence. Respondent claimed that the petition as time barred because Petitioner did not serve process on him until one day after the expiration of the three-year limitation period. The trial court agreed, determining that there was no proof of timely delivery of process to the state marshal for purposes of section 52-593a because the state marshal did not endorse the date of delivery, and Petitioner failed to provide support for the proposition that a fax constituted personal delivery as a matter of law. The Supreme Court reversed, holding that Petitioner satisfied the personal delivery requirement via successfully faxing process to the state marshal for service. View "Johnson v. Preleski" on Justia Law

The Supreme Court affirmed the determination of the trial court that the collapse provisions of Insured's homeowners insurance policy unambiguously foreclosed coverage under the circumstances of this case, holding that the trial court did not err.Insured brought this action against Insurer claiming that Insurer breached the homeowners insurance policy it issued by denying coverage for cracks in the basement walls of Insured's home under the collapse provisions of the policy. The trial court granted summary judgment for Insurer because the policy defined "collapse" as "an abrupt falling down or caving in" of the home and because Insured's remained standing and was in no imminent danger of falling down. On appeal, Insured argued that the definition of "collapse" in Beach v. Middlesex Mutual Assurance Co., 532 A.2d 1297 (Conn. 1987), applied. The Supreme Court affirmed, holding that, even if this Court agreed that the definition of collapse contained in the policy was ambiguous and that, therefore, Beach's substantial impairment standard applied to Insured's claim, Insured's claim of coverage would fail even under that standard. View "Jemiola v. Hartford Casualty Insurance Co." on Justia Law

The Supreme Court answered certified questions concerning the application of Connecticut insurance law in this action to recover damages for, among other things, breach of an insurance contract, concluding that the definition of "collapse" in Beach v. Middlesex Mutual Assurance co., 532 A.2d 1297 (Conn. 1987), applied in this case.In Beach, the Supreme Court held that the term "collapse," when not defined in a homeowners insurance policy, is "sufficiently ambiguous to include coverage for any substantial impairment of the structural integrity" of the insureds' home. At issue before the Supreme Court was whether the Beach standard also required a showing that the building was in imminent danger of falling down or caving in. The Supreme Court concluded that it does, holding that the "substantial impairment of structural integrity" standard requires a showing that the building is in imminent danger of falling down or caving in, or in other words, in imminent danger of an actual collapse. View "Vera v. Liberty Mutual Fire Insurance Co." on Justia Law

The Supreme Court reformulated a certified question concerning the application of Connecticut insurance law in this action to recover damages for, among other things, breach of an insurance contract, concluding that the definition of "collapse" in Beach v. Middlesex Mutual Assurance Co., 532 A.2d 1297 (Conn. 1987), applied in this case.At issue before the Supreme Court was the definition of the term "collapse" in a homeowners insurance policy, when otherwise undefined, as set forth in Beach v. Middlesex Mutual Assurance Co., 532 A.2d 1297 (Conn. 1987), as "any substantial impairment of the structural integrity" of the insureds' home. The United States District Court for the District of Connecticut certified questions to the Supreme Court regarding whether Beach's definition of collapse applied in this case. Insureds sued Insurer, claiming that their homeowners insurance policy covered the cracking and tumbling of their concrete basement walls. The Supreme Court held (1) the Beach standard applied to Insureds' policy; (2) the "substantial impairment of structural integrity" standard requires proof that the home is in imminent danger of falling down; and (3) the term "foundation" unambiguously encompasses the basement walls of Insureds' home. View "Karas v. Liberty Insurance Corp." on Justia Law

The Supreme Court reversed the judgment of the Appellate Court affirming the judgment of the habeas court denying Petitioner's amended petition for a writ of habeas corpus, holding that the Appellate Court improperly raised and decided the unpreserved issue of waiver without first providing the parties with an opportunity to be heard on that issue.Petitioner pled guilty under the Alford doctrine to one count of home invasion. Thereafter, Petitioner commenced this habeas action alleging that his trial counsel had provided ineffective assistance by failing to file a motion to discuss the home invasion charge. The habeas court denied the petition. The Appellate Court affirmed on an alternative ground, concluding that Petitioner waived his ineffective assistance claim by virtue of the entry and acceptance of his Alford plea. The Supreme Court reversed and remanded the case, holding that because the parties were not provided an opportunity to be heard on waiver it was improper for the Appellate Court to raise and decide that issue. View "Diaz v. Commissioner of Correction" on Justia Law

The Supreme Court affirmed the judgment of the trial court denying Defendant's motion to suppress photographs and videos of suspected child pornography that the police recovered from computer equipment and other media storage seized from Defendant's residence pursuant to a search warrant, holding that the search warrant affidavit supported a finding of probable cause.On appeal, Defendant argued that the search warrant was not supported by probable cause because the issuing judge could not reasonably have inferred from descriptions in the affidavit of two photographs of nude children that the photographs were lascivious. The Supreme Court affirmed, holding that the totality of the circumstances described in the affidavit and the reasonable inferences drawn therefore supported a finding of probable cause to believe that a there was a substantial chance that a search of Defendant's residence would uncover evidence of possession of child pornography. The Court further declined Defendant's invitation to adopt a more demanding standard for assessing whether there is probable cause to issue a search warrant. View "State v. Sawyer" on Justia Law

In this negligence action, the Supreme Court reversed the judgment of the Appellate Court declining to review Plaintiff's claim that the trial court improperly rejected her request to instruct the jury that Defendants had a nondelegable duty to maintain the premises where she slipped and fell, holding that the Appellate Court erred in concluding that the general verdict rule barred appellate review of Plaintiff's jury instruction claim.Plaintiff sued Defendants, her landlords, for injuries she suffered when she slipped and fell on a staircase outside of her apartment building. The trial court entered judgment for Defendants. Plaintiff appealed, challenging the trial court's refusal to instruct the jury that Defendants, as the possessors of real property, had a nondelegable duty to maintain the premises. The Appellate Court declined to review Plaintiff's claims, concluding that because Plaintiff failed to object when the trial court denied her request to submit her proposed interrogatories to the jury the general verdict rule applied. The Supreme Court reversed, holding that the general verdict rule did not apply because Plaintiff had requested that the trial court submit her properly framed interrogatories to the jury and had objected when it denied her request. View "Garcia v. Cohen" on Justia Law

The Supreme Court affirmed the decision of the Compensation Review Board, which reversed the decision of the Workers' Compensation Commissioner denying benefits to Plaintiff pursuant to Conn. Gen. Stat. 7-433c(a), holding that the Board incorrectly determined that Plaintiff's heart disease claim was untimely.The Commissioner found that Plaintiff was neither diagnosed with heart disease nor filed a claim for that disease under section 7-433c until after he had retired. Therefore, the Commissioner concluded that Plaintiff's disease and resulting disability were not suffered while Plaintiff was employed by Defendant and that even if Plaintiff was developing heart disease while he was employed by Defendant that was not sufficient to make the claim compensable. The Board reversed, concluding that it was reasonable to infer that Plaintiff's heart disease was the sequela of his accepted claim under section 7-433c for hypertension. The Supreme Court affirmed, holding (1) Plaintiff's initial claim for hypertension met the requirements of section 7-433c, was timely, and was compensable; and (2) the Board reasonably concluded that Plaintiff's heart disease was the sequela of his hypertension, which was the injury at issue in his primary claim. View "Coughlin v. Stamford Fire Department" on Justia Law

The Supreme Court affirmed the decision of the Compensation Review Board, which vacated the decision of the Workers' Compensation Commissioner dismissing Plaintiff's claim for benefits brought pursuant to Conn. Gen. Stat. 7-433c(a), holding that Plaintiff met the jurisdictional prerequisites of section 7-433c and that, on remand, the Commissioner shall determine whether Plaintiff's hypertension was a substantial factor in his subsequent development of heart disease.The Commissioner found that Plaintiff was not entitled to benefits for heart disease because he failed to file a notice of new claim within one year of his diagnosis. In making this finding, the Commissioner rejected Plaintiff's argument that his heart disease diagnosis was the sequela of his compensable claim for hypertension. The Board vacated the Commissioner's dismissal because the Commissioner did not present findings as to whether Plaintiff's heart disease was caused by his hypertension or constituted a new injury. The Supreme Court affirmed and remanded the case, holding (1) when a plaintiff has a compensable claim for hypertension under section 7-433c, the plaintiff may also be eligible for benefits for subsequent heart disease if his heart disease is causally related to his hypertension; and (2) Plaintiff was not required to file a notice of new claim in order to pursue benefits for his heart disease. View "Dickerson v. Stamford" on Justia Law