Justia Connecticut Supreme Court Opinion Summaries

by
The Supreme Court affirmed the judgment of the Appellate Court dismissing Petitioner's appeal from the trial court's denial of his request for leave to file a late petition for certification to appeal from the court's judgment denying his petition for a new trial, holding that the trial court did not abuse its discretion in concluding that certification to appeal should be denied.The trial court denied Petitioner's petition on the ground that Petitioner's claims were "meritless and too late." Petitioner appealed, claiming that the trial court improperly considered the merits of the petition rather than the reasons for the delay or other factors relevant to permitting a late filing. The Appellate Court dismissed Petitioner's appeal. The Supreme Court affirmed, holding that the trial court (1) abused its discretion by failing to engage in the proper analysis to determine whether to excuse the late petition for certification; and (2) did not abuse its discretion in determining that the petition failed to raise issues warranting certification. View "Mitchell v. State" on Justia Law

Posted in: Criminal Law
by
The Supreme Court affirmed the decision of the appellate court affirming the judgment of the trial court convicting Defendant of three counts of sexual assault in the first degree and other crimes, holding that neither the structure nor the content of the prosecutor's closing argument deprived Defendant of his constitutional rights.On appeal, Defendant argued that the prosecutor deprived him of his constitutional rights to present a closing argument and to a fair trial by reserving her analysis of certain evidence for the rebuttal portion of closing argument and by mischaracterizing other evidence during rebuttal. The appellate court affirmed. The Supreme Court affirmed, holding that Defendant's claims of prosecutorial impropriety failed. View "State v. Gonzalez" on Justia Law

by
The Supreme Court affirmed the judgment of the appellate court, which affirmed the judgment of the habeas court denying Petitioner's amended petition for a writ of habeas corpus, holding that Petitioner failed to demonstrate that he was prejudiced by his trial counsel's failure to object to the prosecutor's improper comments during closing argument at Petitioner's criminal trial.Petitioner was convicted of murder. On appeal, the appellate court concluded that at least one of the prosecutor's comments during closing argument violated Petitioner's constitutional right to a fair trial but that Petitioner had not been prejudiced by the improper remarks. The Supreme Court affirmed, holding that the failure to Petitioner's criminal trial counsel to object to the prosecutor's improper remarks did not undermine the Court's confidence in the verdict. View "Ross v. Commissioner of Correction" on Justia Law

by
The Supreme Court affirmed the judgment of the appellate court affirming Defendant's conviction of sexually assaulting a twelve-year-old girl and sentencing him to a total effective prison term of thirty-three years, holding that there was no error.On appeal, Defendant argued that the trial court violated his due process right at sentencing by increasing his sentence because of his unwillingness to apologize to the victims. The appellate court affirmed, holding that the record did not support Defendant's contention. The Supreme Court affirmed, holding that the prison term imposed on Defendant did not give rise to an inference that the court punished him for refusing to issue an apology to the victims. View "State v. Angel M." on Justia Law

Posted in: Criminal Law
by
The Supreme Court affirmed the judgment of the trial court revoking Defendant's probation and sentencing him to an effective term of imprisonment of two years, holding that the trial court did not err in denying Defendant's motion to dismiss the violation of probation charge.Defendant pleaded guilty to illegal possession of child pornography in the second degree. After Defendant was released on probation he was charged with violating his probation for failing to complete sex offender treatment. The trial court found that Defendant had violated his probation, revoked his probation, and sentenced him to a term of imprisonment of six years. Defendant appealed, arguing that the condition of probation on which the violation of probation charge was predicated violated his Fourteenth Amendment rights to due process and equal protection and the constitutional prohibition against the imposition of cruel and unusual punishment. The Supreme Court affirmed, holding that Defendant's claims of error lacked merit. View "State v. Imperiale" on Justia Law

Posted in: Criminal Law
by
The Supreme Court affirmed the judgments of the trial court applying the general negligence statute of limitations in Conn. Gen. Stat. 52-584 to Plaintiffs' claims alleging medical negligence instead of the extended limitation period set forth in section 52-577d, holding that the trial court did not err.Plaintiffs were minor patients of Robert Rackliffe, a pediatrician practicing in the early 1970s to the 1980s. Plaintiffs alleged that Rackliffe sexually assaulted them during their annual physical examinations and that Rackliffe's conduct constituted medical negligence. The trial court granted summary judgment in favor of Defendant. The Supreme Court affirmed, holding that section 52-577d did not apply to Plaintiffs' claims sounding in negligence and that the negligence claims were governed by the limitation period set forth in section 52-584. View "Doe v. Rackliffe" on Justia Law

by
The Supreme Court reversed the judgment of the appellate court reversing the judgment of the trial court convicting Defendant of burglary in the third degree, attempt to commit tampering with physical evidence, and attempt to commit arson in the second degree, holding that the appellate court improperly addressed an issue of evidentiary sufficiency sua sponte without calling for supplemental briefing.The appellate court reversed Defendant's conviction on the ground that there was insufficient evidence for the jury to have reasonably concluded that Defendant intended to tamper with physical evidence. The Supreme Court reversed, holding that the appellate court improperly decided an issue of evidentiary sufficiency sue sponte without ordering supplemental briefing, as required by Blumberg Associates Worldwide, Inc. v. Brown & Brown of Connecticut, Inc., 84 A.3d 840 (Conn. 2014). View "State v. Stephenson" on Justia Law

Posted in: Criminal Law
by
The Supreme Court reversed the judgment of the appellate court affirming Defendant's conviction of assault in the second degree, holding that the appellate court erred in determining that the trial court's investigative inadequacy jury instruction did not mislead the jury or otherwise deprive Defendant of his right to present an investigative inadequacy defense.The jury found Defendant guilty of assault in the second degree, and the court rendered judgment in accordance with the verdict. On appeal, Defendant argued that the jury instructions deprived him of his right to present a defense of investigative inadequacy. The appellate court rejected Defendant's claim and affirmed. The Supreme Court reversed, holding (1) the model jury instruction utilized by the trial court in this case failed properly to instruct the jury; and (2) the instructional error was not harmless. View "State v. Gomes" on Justia Law

Posted in: Criminal Law
by
In this action for a temporary injunction in connection with the intake and discharge of water from the Long Island Sound and nearby bodies of water by Dominion Nuclear Connecticut, Inc., the owner and operator of a nuclear power station, the Supreme Court ultimately affirmed the judgments in favor of Defendants, holding that the trial court did not err.This case was before the Supreme Court for the third time. Plaintiff brought this action under the Connecticut Environmental Protection Act of 1971 (CEPA), Conn. Gen. Stat. 22a-14 et seq., against Dominion and the Department of Environmental Protection, challenging the Department's decision to issue a National Pollutant Discharge Elimination system permit to Dominion to authorize the intake and discharge of water by the plant, arguing that the permit renewal proceeding was inadequate. On remand for the second time from the Supreme Court, the trial court rendered judgment in favor of Defendants. The Supreme Court affirmed, holding (1) the administrative proceeding was not inadequate; and (2) Plaintiff's remaining claims on appeal were inadequately briefed. View "Burton v. Department of Environmental Protection" on Justia Law

by
The Supreme Court reversed the judgment of the appellate court concluding that Conn. Gen. Stat. 14-55 was not repealed by a sequence of contradictory public acts relating to that statute, holding that section 14-55 has not been repealed.Plaintiff filed an administrative appeal challenging the decision of the Zoning Board of Appeals of the City of Stamford to grant a certificate of approval of the location for Defendants' used car dealership. The trial court denied the administrative appeal, but the appellate court reversed. At issue was whether the suitability analysis mandated by section 14-55 was still required in order to obtain a certificate of approval for the location of a used car dealership, despite subsequent revisions of the General Statutes listing that provision as having been repealed. The Supreme Court reversed, holding that the appellate court erred in concluding that section 14-55 had been repealed. View "One Elmcroft Stamford, LLC v. Zoning Board of Appeals" on Justia Law