Justia Connecticut Supreme Court Opinion Summaries

The Supreme Court affirmed the decision of the trial court rendering summary judgment in favor of Defendant, as executor of the estate of Robert Rackliffe, on the ground that Plaintiffs' negligence claims were time barred, holding that the extended limitation period set forth in Conn. Gen. Stat. 52-577d did not apply to Plaintiffs' negligence claims for personal injuries brought against the alleged perpetrator of a sexual assault.Seven plaintiffs, each of whom were minors at the time of the alleged assaults, alleged that Rackliffe's conduct constituted both intentional sexual assault and medical negligence. Defendant sought summary judgment as to the counts sounding in negligence, arguing that those counts were time barred by Conn. Gen. Stat. 52-584. The trial court granted summary judgment as to all of the negligence counts. Plaintiffs subsequently withdrew their additional claims and appealed. The Supreme Court affirmed, holding that Plaintiffs' negligence claims were governed by the three-year limitation period set forth in section 52-584 and that section 52-577d did not apply to Plaintiffs' claims. View "Doe v. Rackliffe" on Justia Law

The Supreme Court reversed the judgment of the appellate court, which reversed the judgment of the trial court convicting Defendant of burglary in the third degree and other offenses in connection with a break-in, holding that the appellate court improperly addressed an issue of evidentiary sufficiency sua sponte without calling for supplemental briefing, as required by Blumberg Associates Worldwide, Inc. v. Brown & Brown of Connecticut, Inc., 84 A.3d 840 (Conn. 2014).On appeal, the appellate court reversed Defendant's conviction for tampering with physical evidence, concluding that there was insufficient evidence for the jury to have reasonably concluded that Defendant intended to tamper with the evidence at issue. In reaching its decision, the appellate court recognized that the issue was distinct from Defendant's sufficiency argument on appeal. The Supreme Court reversed, holding that the appellate court violated the mandate in Blumberg by raising a different claim of evidentiary sufficiency sua sponte, without calling for supplemental briefing from the parties. View "State v. Stephenson" on Justia Law

The Supreme Court affirmed the judgment of the appellate court affirming the judgment of the trial court revoking Defendant's probation following an incident in which he allegedly robbed and threatened a customer, Lawrence Welch, at a Dunkin' Donuts store, holding that Welch's identification of Defendant was reliable notwithstanding the inherent suggestiveness of the showup procedure.After Defendant was charged with violating a condition of his probation he filed a motion to suppress Welch's identification of him, claiming that the showup procedure violated his due process rights. The trial court denied the motion and found that Defendant had violated his probation. The appellate court affirmed, concluding that the identification procedure was not unnecessarily suggestive due to the exigencies of the ongoing investigation. The Supreme Court affirmed, holding that, considering the totality of the circumstances, Welch's identification of Defendant was reliable. View "State v. Ruiz" on Justia Law

The Supreme Court affirmed the judgment of the appellate court affirming the judgment of the trial court finding that Defendant, East Coast Swappers, LLC, had violated the Connecticut Unfair Trade Practices Act (CUTPA), Conn. Gen. Stat. 42-110a et seq., holding that the trial court abused its discretion when it failed to award Plaintiff attorney's fees.The trial court found that Defendant had violated CUTPA and awarded Plaintiff compensatory damages. The court, however, declined to award punitive damages or attorney's fees. On appeal, Plaintiff argued that the Court should adopt a presumption whereby a plaintiff prevailing in a CUTPA action should ordinarily recover attorney's fees under section 42-110g(d) unless the award would be unjust. The Supreme Court declined to adopt Plaintiff's suggested presumption but nevertheless reversed, holding that the trial court abused its discretion by failing to award Plaintiff attorney's fees. View "Stone v. East Coast Swappers, LLC" on Justia Law

The Supreme Court affirmed the judgment of the trial court granting the City of Waterbury's motion to dismiss this action seeking to have the trial court confirm an interest arbitration award, holding that the trial court correctly determined that it lacked subject matter jurisdiction to confirm the award under Conn. Gen. Stat. 52-417.Brass City Local, CACP (the union), a collective bargaining unit that represented employees of the Waterbury Police Department, brought this action seeking confirmation of an arbitration award issued in accordance with the provisions of Conn. Gen. Stat. 7-473c of the Municipal Employees Relations Act (MERA). The trial court granted the City's motion to dismiss, concluding that the court lacked subject matter jurisdiction to consider the union's application to confirm. The Supreme Court affirmed, holding that the trial court correctly determined that it lacked jurisdiction under section 52-417 to confirm an interest arbitration award issued pursuant to section 7-473c. View "Brass City Local, CACP v. City of Waterbury" on Justia Law

The Supreme Court reversed the judgment of the appellate court affirming Defendant's conviction of murder, holding that the appellate court improperly upheld the trial court's denial of Defendant's motion for a Porter hearing on the reliability of ballistics evidence based solely on the holding in State v. Legnani, 951 A.2d 674 (Conn. 2008).On appeal, Defendant argued that reports issued by the National Academy of Sciences called into question the reliability of methodologies employed in firearm and toolmark examinations and that a Porter hearing was necessary to determine if such evidence was admissible. The trial court construed Legnani by concluding that a Porter hearing on the reliability of firearm and toolmark examinations was not necessary. The Supreme Court reversed, holding that the trial court erred in denying Defendant's motion for a Porter hearing based solely on Legnani without considering new evidence offered by Defendant, and the error was not harmless. View "State v. Raynor" on Justia Law

The Supreme Court reversed the judgment of the appellate court holding that the special credibility instruction required in State v. Patterson, 886 A.2d 777 (Conn. 2005), did not apply to an incarcerated informant who offered his testimony that the defendant confessed to him when they socialized outside of prison in exchange for favorable treatment of the informant by the state, holding that the trial court improperly denied Defendant's unopposed request for a jailhouse informant instruction.Defendant was convicted of murder, carrying a pistol without a permit, and criminal possession of a firearm. At the conclusion of trial, defense counsel requested a special credibility instruction with respect to the testimony of a witness in accordance with Patterson, arguing that a jailhouse informant instruction was warranted. The state did not object to the requested instruction, but the trial court declined to issue it and instead issued a general credibility instruction. The appellate court affirmed. The Supreme Court reversed, holding that, under the facts of this case, the trial court improperly denied Defendant's unopposed request for a jailhouse informant instruction. View "State v. Jones" on Justia Law

The Supreme Court affirmed the judgment of the appellate court affirming the trial court's judgment of conviction of murder, holding that the appellate court correctly concluded that any error relating to the admission of testimony from a witness called during the state's case on rebuttal was harmless.On appeal, Defendant argued that the testimony of Mark Manganello, the witness at issue, fatally undermined her theory of self defense and that the testimony likely had a substantial effect on the jury's verdict. The Supreme Court disagreed, holding that the appellate court properly concluded that any evidentiary error committed by the trial court with respect to the admission of Manganello's testimony was necessarily harmless. View "State v. Carey" on Justia Law

The Supreme Court reversed the judgment of the appellate court affirming Defendant's conviction of six counts of sexual assault and four counts of risk of injury to a child from the sexual abuse of his girlfriend's daughter, J, holding that the trial court erred in excluding screenshot photographs of text messages purportedly sent by J to Defendant's niece.Specifically, the Supreme Court held (1) the appellate court correctly upheld the admission into evidence of a video recording of a forensic interview of J by a nonmedical professional under the medical diagnosis and treatment exception to the hearsay rule; but (2) the appellate court incorrectly concluded that the trial court had properly excluded J's text messages on the ground that they had not been sufficiently authenticated, and the improper exclusion of the text messages requires reversal of the judgment and a new trial. View "State v. Manuel T." on Justia Law

The Supreme Court reversed the judgment of conviction rendered by the trial court following Defendant's conditional plea of nolo contendere to the charge of possession of a controlled substance with intent to sell, holding that the trial court erred in denying Defendant's motion to suppress.Defendant sought to suppress evidence seized after his warrantless detention in the parking lot of a multiunit apartment building. The trial court denied the suppression motion. The Supreme Court reversed, holding that Defendant was not an "occupant" within the "immediate vicinity" of the premises subject to a search warrant under the exception to the Fourth Amendment's warrant requirement set forth in Michigan v. Summers, 452 U.S. 692 (1981), and Bailey v. United States, 568 U.S. 186 (2013). View "State v. Rolon" on Justia Law