Justia Connecticut Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the trial court convicting Defendant of murder and risk of injury to a child, holding that none of Defendant's claims of error warranted reversal of his convictions.Defendant was convicted of killing his seven-month-old son in an incident in which Defendant also attempted suicide. The Supreme Court affirmed, holding (1) the trial court did not err in denying Defendant's motion to suppress certain evidence arising from statements that Defendant had made to the police while in the hospital; (2) even assuming that the trial court improperly admitted Defendant's statements made at the hospital in violation of Conn. Gen. Stat. 54-lo because the interview was not recorded, any such error was harmless; and (3) the trial court did not err by precluding Defendant from introducing into evidence Defendant's offer to plead guilty to manslaughter in exchange for twenty-five years' incarceration. View "State v. Tony M." on Justia Law

The Supreme Court affirmed the judgment of the trial court determining that a money judgment against Department of Transportation had been satisfied, holding that the Department satisfied its judgment to White Oak Corporation.White Oak was awarded a money judgment in the amount of $8,362,308 against the Department after an arbitration proceeding. The Office of the State Comptroller paid the judgment on behalf of the Department and withheld $1,642,312 for taxes White Oak had owed to the state. White Oak filed a motion asserting that the doctrine of collateral estoppel precluded the comptroller from reducing the payment by any amount for taxes owed because, during a prior arbitration proceeding between the parties, the Department had alleged but failed to prove its claim for taxes owed to the state. The trial court rejected White Oak's claim. The Supreme Court affirmed, holding that Conn. Gen. Stat. 12-39g imposed a mandatory obligation on the comptroller to reduce the amount paid to White Oak by the amount of taxes owed to the state, as those taxes were not the subject of a timely filed administrative appeal. View "Department of Transportation v. White Oak Corp." on Justia Law

The Supreme Court reversed in part the judgment of the Appellate Court concluding that Defendant failed to establish that his Sixth Amendment right to confront witnesses against him was violated at trial, holding that, under the specific circumstances of this case, Defendant established a violation of his right to confrontation.Defendant was found guilty of felony murder, manslaughter in the first degree with a firearm, and other offenses. At trial, the State introduced evidence that Defendant's DNA profile, which had been generated from a post arrest buccal swab, matched the DNA found on evidence from the crime scene. The State, however, did not call as a witness the analyst who processed the buccal swab and generated the DNA profile used in the comparison. On appeal, the Appellate Court concluded that Defendant's Sixth Amendment claim failed because the admission of DNA evidence did not violate Defendant's constitutional right to confrontation. The Supreme Court reversed, holding that the generation of DNA's profile was testimonial and that Defendant's Sixth Amendment right to confront witnesses against him was violated. View "State v. Walker" on Justia Law

In this negligence action, the Supreme Court reversed the Appellate Court's decision determining that the trial court did not abuse its discretion when it denied Plaintiff's motion to set aside the jury verdict for Defendants and for a new trial, holding that the jury's responses to certain interrogatories were legally inconsistent.Plaintiff brought this action against Johnley Sainval, a taxicab driver, and Sainval's employer seeking damages for serious injuries she sustained when she was struck by a taxicab that had been stolen from Sainval after Sainval left the vehicle unattended with the key in the ignition. The jury found that Sainval was negligent and that Sainval's negligence was a proximate cause of Plaintiff's injuries but that Defendants were not liable for Plaintiff's injuries because the accident was not within the scope of the risk created by Sainval's negligence. Plaintiff filed a motion to set aside the verdict and for a new trial, but the trial court denied the motion. The Appellate Court affirmed. The Supreme Court reversed, holding (1) the superseding cause doctrine was inapplicable to the present case; but (2) Plaintiff was entitled to a new trial because the interrogatory responses on which the jury verdict was based were inconsistent as a matter of law. View "Snell v. Norwalk Yellow Cab, Inc." on Justia Law

The Supreme Court reversed the judgment of the Appellate Court affirming the trial court's judgment of strict foreclosure in favor of Plaintiff's mortgagee, U.S. Bank National Association, holding that the Appellate Court erred in striking Defendant's special defenses and counterclaims.After Plaintiff commenced this foreclosure action Defendant filed an answer special defenses, and counterclaims. The special defenses sounded in equitable estoppel and unclean hands and the counterclaims sounded in negligence and violations of the Connecticut Unfair Trade Practices Act (CUTPA), Conn. Gen. Stat. 42-110a et seq. The trial court granted Plaintiff's motion to strike all of the special defenses and counterclaims on the grounds that the alleged misconduct did not relate to the making, validity, or enforcement of the note or mortgage. The Appellate Court affirmed. The Supreme Court reversed, holding that a mortgagee's misconduct that hinders a mortgagor's efforts to cure a default and adds to the mortgagor's debt while the mortgagor is making good faith efforts is a proper basis for special defenses or counterclaims in that action. View "U.S. Bank National Ass'n v. Blowers" on Justia Law

The Supreme Court affirmed the judgment of the trial court denying Defendant's petition seeking erasure of an earlier finding that he had violated his probation, holding that the trial court properly rejected Defendant's argument that Conn. Gen. Stat. 54-142d compelled the erasure of a finding of a violation of probation that Defendant claimed was premised on the now decriminalized offense of possession of less than one-half ounce of marijuana.In State v. Menditto, 110 A.3d 410 (Conn. 2015), the Supreme Court held that Public Acts 2011, No. 11-71 "decriminalized" the possession of less than one-half ounce of marijuana for purposes of the erasure statute, section 54-142d. In his petition, Defendant argued that because his 2012 marijuana conviction had been erased from his record, no conviction any longer supported the violation of probation finding. The trial court rejected Defendant's argument. The Supreme Court affirmed, holding that section 54-142d did not entitle Defendant to erasure of the records pertaining to the 2012 finding that he violated his probation. View "State v. Dudley" on Justia Law

The Supreme Court affirmed the judgment of the Appellate Court dismissing Appellant's appeal from the judgment of the habeas court denying Appellant's amended petition for a writ of habeas corpus, holding that Appellant failed to meet his burden of showing that his criminal trial counsel rendered ineffective assistance by failing to present the testimony of a second alibi witness to support his defense.On appeal, Appellant claimed that the Appellate Court incorrectly concluded that the habeas court did not abuse its discretion in denying certification to appeal because he established that his counsel had performed deficiently. The Supreme Court disagreed, holding (1) it was not debatable among jurists of reason that Appellant rendered ineffective assistance; and (2) therefore, the Appellate Court correctly concluded that the habeas court did not abuse its discretion in denying Appellant's petition for certification to appeal. View "Meletrich v. Commissioner of Correction" on Justia Law

The Supreme Court reversed the judgment of the trial court rendering summary judgment in favor of Defendants after concluding that Plaintiff's unjust enrichment claims were governed by Delaware law and were thus time-barred, holding that Connecticut law, rather than Delaware law, controlled the timeliness of Plaintiff's claims.Plaintiff brought unjust enrichment claims against Defendants seeking recovery for alleged overpayments issued to Defendants by Plaintiff's putative predecessor in interest pursuant to a limited partnership agreement. The trial court concluded that Plaintiff's claims were governed by Delaware law and were therefore time-barred. The Supreme Court reversed, holding (1) Delaware law governed the substantive rights and liabilities of the parties arising out of the limited partnership agreement, but Connecticut law governed matters of judicial administration and procedure; and (2) because Plaintiff's unjust enrichment claims had a common-law origin, the limitation period properly was characterized as procedural, and therefore, Connecticut law governed the timeliness of Plaintiff's unjust enrichment claims. View "Reclaimant Corp. v. Deutsch" on Justia Law

The Supreme Court affirmed the judgment of the trial court determining that Plaintiff's various statements and gestures regarding gun violence and mass shootings that led to his expulsion from the university were true threats that were not protected by the First Amendment to the United States Constitution, holding that Plaintiff's statements and gestures made on a public university campus were true threats.A university expelled Plaintiff from the university's campus after finding that Plaintiff's statements and actions with respect to gun violence had violated four provisions of the university's student code of conduct. Plaintiff brought this action alleging, among other things, that his expulsion violated his constitutional rights to due process and to freedom of speech. The trial court entered judgment in favor of Defendants. Plaintiff appealed, asserting that his statements and gestures were hyperbolic and humorous statements on a matter of public concern. The Supreme Court disagreed, holding that Plaintiff's statements and gestures were true threats that were not protected by the First Amendment. View "Haughwout v. Tordenti" on Justia Law

The Supreme Court affirmed Defendant's conviction of sexual assault in a cohabiting relationship, holding that alleged improper comments made by the prosecutor during closing argument and cross-examination did not warrant reversal of Defendant's conviction.On appeal, Defendant argued that the prosecutor made an impermissible "generic tailoring" argument by commenting in closing argument that the jury should discredit Defendant's trial testimony and that this comment violated his confrontation rights under the Connecticut Constitution. Defendant further argued that the prosecutor engaged in impermissible conduct in violation of his due process right to a fair trial pursuant to State v. Singh, 793 A.2d 226 (Conn. 2002). The Supreme Court affirmed, holding (1) the prosecutor's tailoring comment constituted a specific, rather than a generic, tailoring argument; and (2) assuming that Singh was violated, Defendant was not deprived of his due process right to a fair trial. View "State v. Weatherspoon" on Justia Law