Justia Connecticut Supreme Court Opinion Summaries

In this postdissolution matter the Supreme Court affirmed the judgment of the Appellate Court reversing the decision of the trial court granting Defendant's motion for sanctions and for contempt, holding that there was no basis to support the award of attorney's fees and costs.This matter stemmed from the parties' oral stipulation following a motion for modification of alimony and the trial court's adoption of that stipulation as a court order. Subsequent litigation efforts saw Defendant attempting to carry the order into effect and Plaintiff challenging the order. At issue was the court's decision to grant Defendant's postjudgment motion for sanctions and for contempt and awarding Defendant the litigation expenses he had incurred following the entry of the order adopting the stipulation. The Appellate Court reversed the trial court's judgment of contempt. The Supreme Court affirmed and further concluded that the sanction for litigation misconduct must be reversed, holding that, insofar as the award was based on contempt, it could not stand on any of the grounds articulated by the trial court, and insofar as the award was based on litigation misconduct, it lacked the requisite findings. View "Puff v. Puff" on Justia Law

The Supreme Court affirmed the judgment of the Appellate Court affirming the judgment of the trial court terminating Father's parental rights as to his child, holding that Father's parental rights were properly terminated for lack of an ongoing parent-child relationship.Father was incarcerated when the child was two years old. At the time of the termination trial, the child, who was six years old, had no knowledge or memory of Father. On appeal, Father argued that the virtual infancy and interference exceptions to the lack of an ongoing parent-child relationship ground for the termination of parental rights was applicable because the child was only two years old when Father's incarceration separated them, and the circumstances of this case rendered contact impossible during his incarceration. The Appellate Court affirmed. The Supreme Court affirmed, holding that the interference and virtual infancy exceptions were inapplicable as a matter of law, and therefore, the Appellate Court properly upheld the trial court's termination of Father's parental rights. View "In re Tresin J." on Justia Law

The Supreme Court affirmed the judgment of the appellate court affirming Defendant's conviction of conspiracy to commit robbery in the first degree, holding that there was no clear, obvious or indisputable error warranting reversal of Defendant's conviction.On appeal, Defendant argued that the trial court failed to instruct the jury on an essential element of the crime, as required by State v. Pond, 50 A.30 950 (Conn. 2012). The appellate court held that there was no obvious or undebatable error in the jury instructions and that, even if the instructions were erroneous, there was no manifest injustice necessitating reversal of the conviction. The Supreme Court affirmed, holding that the trial court's jury instructions were sufficient to guide the jury in arriving at its verdict. View "State v. Blaine" on Justia Law

The Supreme Court reversed the judgment of the trial court with respect to an award of damages, holding that Conn. Gen. Stat. 51-183c applies when the Supreme Court reverses the trial court's judgment as to damages only and remands the case to the trial court to take new evidence and recalculate damages.Plaintiff brought this action to enjoin Defendant from violating certain conservation restrictions on certain of Defendant's real property. The judge trial referee rendered judgment for Plaintiff. The Supreme Court reversed in part and remanded the case to the superior court with direction to recalculate the award of attorney's fees and damages. The same judge trial referee denied Defendant's motion to disqualify and issued certain orders from which Defendant appealed. The Supreme Court reversed the judgment as to damages, holding that section 51-183c, which precludes a judge who tried a case without a jury from trying the case again after the reviewing court reverses the judgment, applied in this case, and the judge trial referee was required to disqualify himself on remand after the first appeal. View "Lyme Land Conservation Trust, Inc. v. Platner" on Justia Law

The Supreme Court affirmed the judgment of the Appellate Court concluding that the record was inadequate to review Defendant's challenge under Batson v. Kentucky, 476 U.S. 79 (1986), to the prosecutor's exercise of a peremptory challenge on a prospective juror, holding that the trial court did not commit clear error in finding that the prosecutor did not engage in purposeful discrimination when he peremptorily challenged the juror.Defendant was convicted of assault in the first degree as an accessory and conspiracy to commit assault in the first degree. On appeal, Defendant challenged the prosecutor's exercise of a peremptory challenge on a prospective juror on the basis of his employment history. The record, however, did not indicate the race or ethnicity of both the prospective juror and one of the two jurors whom Defendant pinpointed as examples of disparate treatment by the prosecutor. The Appellate Court affirmed. The Supreme Court affirmed, holding that the Appellate Court's well reasoned opinion fully addressed and properly resolved the certified issue. View "State v. Raynor" on Justia Law

The Supreme Court affirmed the judgment of the Appellate Court upholding Defendant's conviction of felony murder on the basis of its rejection of his claim brought under Batson v. Kentucky, 476 U.S. 79 (1986), holding that that the Appellate Court properly affirmed the judgment of conviction but systemic concerns about Batson's failure to address the effects of implicit bias and disparate impact must be referred to a Jury Selection Task Force.Defendant was convicted of felony murder. The Appellate Division affirmed, holding (1) there was no adequate claim that the Appellate Court improperly upheld the trial court's finding that the prosecutor's reasons were not pretextual under the third step of Batson; and (2) although the relief the Court could provide was constrained by Defendant's decision to limit his Batson claims to the Equal Protection Clause, the broader themes of disparate impact and implicit bias that Defendant advanced raised enough concern with the fairness of the criminal justice system for measures to be concerned intended to promote the selection of diverse jury panels in the state's courthouses. View "State v. Holmes" on Justia Law

In this breach of contract action, the Supreme Court reversed in part the trial court's judgment rendered in favor of Plaintiff as to his derivative claims, holding that Plaintiff lacked standing to bring them under the common law or the Connecticut Limited Liability Company Act, Conn. Gen. Stat. 34-100 et seq., but affirmed the judgment for Plaintiff as to his direct claims.This case arose from the deterioration of a business relationship between three individuals. Plaintiff sought damages for, inter alia, breach of contract. Defendants filed a counterclaim. The trial court awarded judgment in part for Plaintiff on the complaint and on the counterclaim. The Supreme Court reversed in part and vacated the court's award of attorney fees under the Connecticut Unfair Trade Practices Act, Conn. Gen. Stat. 42-110a et seq., holding (1) Plaintiff lacked standing to bring his derivative claims; and (2) the trial court properly entered judgment for Plaintiff on his direct counts and did not abuse its discretion in refusing to order Defendants to reimburse Plaintiff for the fees incurred by a joint, court-appointed fiduciary hired to wind up the companies at issue. View "Saunders v. Briner" on Justia Law

The Supreme Court affirmed the judgment of the Appellate Court affirming the trial court's judgment rendered in favor of Defendant after the jury found that, although Defendant had perpetrated an intentional assault and battery on Plaintiff, his use of physical force was justified, holding that the trial court improperly instructed the jury, but the error was harmless.Specifically, the jury found that because Plaintiff was trespassing at the time of the incident and Defendant was acting in the defense of others, Defendant's use of physical force against Plaintiff was justified. The Supreme Court affirmed, holding (1) the trial court improperly instructed the jury on criminal trespass and defense of premises, but the improper jury instruction was harmless because the evidence was sufficient to support the jury's independent finding with respect to the special defense of defense of others; and (2) the evidence was sufficient to support the jury's finding that Defendant was acting in defense of others when he used physical force against Plaintiff. View "Burke v. Mesniaeff" on Justia Law

The Supreme Court affirmed the judgment of the trial court declining to order a new 2019 Democratic primary election for municipal office in the city of Bridgeport pursuant to Conn. Gen. Stat. 9-329a(b), holding that the trial court did not err in determining that Plaintiffs lacked standing to invoke section 9-329a(a)(1) and that Plaintiffs failed to establish that they were entitled to an order directing a new primary election under section 9-329a(a)(2).Plaintiffs, registered Democrats residing in the city, brought this action alleging that improprieties leading up to the primary election rendered the result so unreliable that it must be set aside. The trial court granted Defendants' motion to dismiss the action for lack of aggrievement with respect to Plaintiff's claim brought pursuant to section 9-329a(a)(1) but denied the motion with respect to the claims brought pursuant to section 9-329a(1)(2). After a trial, the court rendered judgment for Defendants. The Supreme Court affirmed, holding (1) Plaintiffs lacked standing to bring a claim under section 9-329a(a)(1) because they were not aggrieved; and (2) Plaintiffs failed to establish that they were entitled to an order directing a new special primary election. View "Lazar v. Ganim" on Justia Law

The Supreme Court reversed the judgment of the habeas court denying Petitioner's successive petition for a writ of habeas corpus, holding that the State's failure to correct certain testimony deprived Petitioner of a new trial.Petitioner was convicted of felony murder. In his second habeas petition, Petitioner alleged, inter alia, that the State deprived him of a fair trial in violation of Brady v. Maryland, 373 U.S. 83 (1963), because the prosecutor failed to correct testimony of the then director of the state police forensic laboratory concerning a red substance on a towel found in the victim's home that, according to the director, had tested positive for blood. The habeas court rejected all of Petitioner's claims, despite the fact that no such test had been conducted and that a subsequent test of the substance proved negative for blood. The Supreme Court reversed, holding that the State's failure to alert the trial court and Petitioner that the director's testimony was incorrect deprived Petitioner of a fair trial. View "Birch v. Commissioner of Correction" on Justia Law