Justia Connecticut Supreme Court Opinion Summaries

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

The Supreme Court affirmed in part and reversed in part the judgment of the Appellate Court reversing Defendant's conviction for murder and three counts of capital felony and remanding the case for a new trial, holding that the Appellate Court erred in concluding that a videotape and expert testimony were improperly excluded during trial.Specifically, the Court held (1) Defendant's corpus delicti claim was reviewable on appeal because it was not merely evidentiary, but the Appellate Court properly concluded that there was sufficient evidence to support the conviction; (2) the Appellate Court erred in concluding that the trial court's erroneous exclusion of the videotape was not harmless; and (3) the Appellate Court erred in concluding that the trial court abused its discretion in precluding the expert testimony proffered by Defendant. View "State v. Leniart" on Justia Law

In this breach of contract and negligent infliction of emotional distress action the Supreme Court affirmed the appellate court's judgment affirming the trial court's judgment denying Defendant's motion for judgment notwithstanding the verdict, holding that there was sufficient evidence to support the jury's verdict for Plaintiff.This action stemmed from Defendant's handling of Plaintiff's homeowner's insurance claim. The jury returned a verdict for Plaintiff on both counts. Defendant filed a motion for judgment notwithstanding the verdict, renewing its motion for a directed verdict, arguing that the verdict was not supported by sufficient evidence presented during Plaintiff's case-in-chief. The trial court denied the motion. On appeal, Defendant contended that the so-called waiver rule - which provides that a defendant waives the right to appeal the trial court's denial of the defendant's motion for directed verdict at the close of the plaintiff's case by opting to introduce evidence in its own behalf - is inapplicable to civil cases in which a trial court reserves decision on a motion for directed verdict. The Supreme Court disagreed, holding that a court reviewing the sufficiency of the evidence to support a jury's verdict must consider all of the evidence considered by the jury returning the verdict, not just the evidence presented in the plaintiff's case-in-chief. View "Riley v. Travelers Home & Marine Insurance Co." on Justia Law

The Supreme Court reversed the judgment of the trial court denying the City of Bridgeport's motion for summary judgment on Plaintiff's complaint that the City was negligent by failing to follow a local emergency service plan and permitting a highway defect to exist, namely, snow, holding that the City was immune for its actions pursuant to Conn. Gen. Stat. 28-13.The trial court rejected the City's argument that this action was barred by common-law governmental immunity and that the City could not invoke the protections of section 28-13 immunity because a genuine issue of material fact existed as to whether the City was actively experiencing a civil preparedness emergency at the time of the death in this case. The Supreme Court reversed, holding (1) an appealable final judgment existed; and (2) there was no genuine issue of material fact with respect to the applicability of section 28-13, and therefore, the trial court should have granted summary judgment. View "Sena v. American Medical Response of Connecticut, Inc." on Justia Law