Justia Connecticut Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the habeas court rendering judgment against Petitioner, a juvenile offender, on his claim that the evolution of Connecticut's "standards of decency" regarding acceptable punishments for children who engage in criminal conduct has rendered the transfer of his case to the regular criminal docket and resultant sentencing unconstitutional, holding that Petitioner was not entitled to relief on his claims.Petitioner, who was fourteen years old when he committed felony murder, argued that his sentence as an adult after his case was automatically transferred to the regular criminal docket violated the state prohibition against cruel and unusual punishment. The habeas court denied relief. The Supreme Court affirmed, holding (1) transferring the case of a fourteen year old defendant to the regular criminal docket comports with evolving standards of decency and, therefore, does not violate the Connecticut constitution; and (2) Petitioner's forty year sentence does not violate the constitutional prohibition against cruel and unusual punishment after the provisions of P.A. 15-84 made Petitioner eligible for parole after serving sixty percent of his original sentence. View "Griffin v. Commissioner of Correction" on Justia Law

The Supreme Court affirmed the decision of the Appellate Court affirming the trial court's dismissal of Defendant's motion to correct an illegal sentence, holding that because Defendant is now eligible for parole under No. 15-84 of the 2015 Public Acts (P.A. 15-84) the Connecticut constitution did not require a resentencing of his unconstitutional sentence.Defendant, a juvenile offender, was convicted of murder and sentenced to thirty-five years' imprisonment. At the time of sentence, Defendant was indelible for parole. Thereafter, decisions by the United States and Connecticut Supreme Courts and enactments by the legislature resulted in changes to the sentencing scheme for juvenile offenders. To comply with federal constitutional requirements the legislature passed P.A. 15-84. As a result, Defendant will be parole eligible after serving twenty-one years. Thereafter, Defendant filed a motion to correct an illegal sentence, asserting a violation of Miller v. Alabama, 467 U.S. 460 (2012). The trial court dismissed the motion for lack of jurisdiction. The Appellate Court ultimately affirmed on the ground decided in State v. Delgado, 151 A.3d 345 (Conn. 2016). The Supreme Court affirmed, holding that, consistent with Delgado and the federal constitution, Defendant's parole eligibility afforded by P.A. 15-84, 1 was an adequate remedy for the Miller violation. View "State v. Williams-Bey" on Justia Law

The Supreme Court affirmed the judgment of the appellate court affirming the judgment of the trial court denying Defendant's motion to correct an illegal sentence, holding that the legislature may and has remedied the constitutional violation in this case with parole eligibility.Defendant, a juvenile offender, was convicted of murder and other offenses. Defendant was originally sentenced to imprisonment for the functional equivalent of his lifetime without the possibility of parole. Subsequently, decisions by the United States and Connecticut Supreme Courts and enactments by the legislature resulted in changes to the sentencing scheme for juvenile offenders. As a result, Defendant will be parole eligible when he is about fifty years old. Defendant filed a motion to correct an illegal sentence based on Miller v. Alabama, 467 U.S. 460 (2012). The trial court ultimately dismissed the motion, concluding that Defendant's claim was moot in light of the United States Supreme Court's holding that Miller applied retroactively. The Supreme Court affirmed, holding (1) parole eligibility afforded by No. 15-84 of the 2015 Public Acts (P.A. 15-84) is an adequate remedy for a Miller violation under the Connecticut constitution; and (2) P.A. 15-84, 1 does not violate the separation of powers doctrine or Defendant's right to equal protection under the federal constitution. View "State v. McCleese" on Justia Law

The Supreme Court affirmed the judgment of the appellate court affirming in part and reversing in part numerous interlocutory decisions made by the trial court in connection with the first and second phases of a trial between R.T. Vanderbilt Company, Inc. and numerous insurance companies, holding that the appellate court's opinion properly resolved the significant issues raised on appeal.These appeals concerned questions of insurance law arising from coverage disputes between Vanderbilt and the insurer defendants, who issued comprehensive general liability insurance policies to Vanderbilt for more than a half a century. The disputes stemmed from lawsuits alleging injuries from exposure to industrial talc containing asbestos that Vanderbilt mined and sold. On interlocutory appeal from several decisions made by the trial court the appellate court affirmed in part and reversed in part. The Supreme Court affirmed, holding (1) the appellate court properly construed the occupational disease exclusions to bar coverage for occupational disease claims brought not only by Vanderbilt employees but also by individuals who contracted an occupational disease while working for other employers; and (2) the appellate court properly resolved the remaining issues on appeal. View "R.T. Vanderbilt Co., Inc. v. Hartford Accident & Indemnity Co." on Justia Law

The Supreme Court held that in case a case involving the termination of parental rights where an indigent parent has a constitutional right to appellate counsel, appointed counsel may not be permitted to withdraw without first demonstrating that the record has been thoroughly reviewed for potential meritorious issues and taking steps to facilitate review of the case for the purpose of determining whether the attorney accurately concluded that any appeal would be meritless.After Mother's parental rights were terminated, counsel was appointed for Mother, who was indigent, to review the matter for a possible appeal. Counsel filed motions to withdraw his appearances for lack of any nonfrivolous issue on which to proceed. The trial court granted counsel's motion to withdraw without requiring the filing of an Anders brief or conducting its own independent review to determine whether any appeal would be frivolous. The Appellate Court then dismissed the appeal, finding that the procedure set forth in Anders is not applicable to the withdrawal of an appellate review attorney in child protection proceedings. The Supreme Court reversed, holding (1) the precise procedures discussed in Anders are not constitutionally mandated, but minimal procedural protections are required; and (2) the minimal procedural protections set forth in this opinion were not afforded to Mother. View "In re Taijha H.-B." on Justia Law

In this action to recover damages for personal injuries resulting from an allegedly defective product the Supreme Court reversed the judgment of the trial court granting summary judgment in favor of Defendants, holding that the amendment to the statute of repose in Number 17-97 of the 2017 Public Acts (P.A. 17-97) retroactively applied to Plaintiff's claims.On appeal, Plaintiff argued that the statute of repose applied to her product liability claims is unconstitutional because it creates two classes of claimants - employees subject to a ten-year statute of repose and nonemployees not subject to the statute of repose if the claimant shows the product was within its useful safe life when the injury occurred. While Defendants' motions for summary judgment were pending the legislature enacted P.A. 17-97, which combined the two classes of claimants by removing the limitation provision applicable to employees. The trial court concluded that P.A. 17-97 was not retroactive and applied the ten-year statute of repose to bar Plaintiff's claims. The Supreme Court reversed, holding that the amendment to the statute of repose in P.A. 17-97 retroactively applied to Plaintiff's claims. The Court remanded to determine whether there is a genuine issue of material fact as to whether the injury occurred during the safe life of the product. View "King v. Volvo Excavators AB" on Justia Law

The Supreme Court affirmed Defendant's conviction of murder and conspiracy to commit murder, holding that there was no error in the trial court's evidentiary rulings.On appeal, Defendant argued that the trial court erred in admitting testimony implicating him in the murder under the coconspirator exception to the hearsay rule and improperly admitted certain state of mind evidence. The Supreme Court disagreed, holding (1) even if the trial court incorrectly admitted the evidence under the coconspirator hearsay exception, the jury's verdict wasn't substantially affected by any such error; and (2) the trial court did not abuse its discretion in determining that the victim's state of mind was relevant as evidence of the deteriorating nature of his relationship with Defendant's gang from which the jury could reasonably infer Defendant's motive to kill him. View "State v. Ayala" on Justia Law

The Supreme Court reversed the judgment of the trial court granting Defendants' motions for summary judgment and dismissing Plaintiff's claim that Defendants' negligent disposal of cigarettes inside an abandoned, privately owned mill in the town ignited a fire that destroyed both the mill and a sewage line in the basement of the mill, holding that Plaintiff was entitled to the benefit of the alternative liability doctrine for the purpose of proving its case at trial.In granting summary judgment, the trial court found that Plaintiff, Connecticut Interlocal Risk Management Agency, as subrogee of its insured, the town of Somers, could not establish which of the defendants' cigarettes had sparked the blaze and therefore could not establish causation. In so holding, the trial court refused Plaintiff's request that it adopt the alternative liability doctrine, as set forth in section 433 B(3) of the Restatement (Second). The Supreme Court reversed and remanded the case, holding (1) when three threshold requirements have been met, the alternative liability doctrine should be recognized as a limited exception to the general rule that the plaintiff in a negligence action must prove that each of the defendants caused the plaintiff's harm; and (2) the three requirements for application of the doctrine were met in this case. View "Connecticut Interlocal Risk Management Agency v. Jackson" on Justia Law

The Supreme Court affirmed the judgment of the appellate court upholding Defendant's convictions for several offenses stemming from the sexual assault of his minor daughter, holding that the evidence was sufficient to support Defendant's conviction for three counts of criminal violation of a restraining order and that the prosecutor did not commit misconduct.Specifically, the Court held (1) there was sufficient evidence from which the jury could conclude that Defendant had "knowledge of the terms of the order" because the court expressly instructed Defendant to limit contact with the children and Defendant heard Spanish language translations of the terms of the order; and (2) the prosecutor's comments and questions were not improper. View "State v. Elmer G." on Justia Law

The Supreme Court reversed the judgment of the Appellate Court concluding that Appellant's claim that his conviction violated the corpus delicti rule was unreviewable on appeal, holding that unpreserved corpus delicti claims are reviewable on appeal.Defendant was convicted of two counts of risk of injury to a child arising from two alleged incidents of sexual misconduct. Defendant appealed, arguing that the only evidence that he committed the second alleged act of misconduct were statements he made to the police and, therefore, that his second conviction violated the corpus delicti rule. Defendant, however, did not raise the corpus delicti issue or challenge the admissibility of his statements at trial. The Appellate Court dismissed the appeal, concluding that corpus delicti is an evidentiary rule that must be raised at trial to be reviewable on appeal. The Supreme Court reversed for the reasons set forth in a companion case decided today, State v. Leniart, __ A.3d __ (2019), holding that Defendant's corpus delicti claim was reviewable on appeal. View "State v. Robert H." on Justia Law