Justia Connecticut Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the trial court granting motions to dismiss Plaintiff's state law claims for vexatious litigation and unfair and deceptive business acts or practices during Plaintiff's underlying bankruptcy proceeding, holding that the trial court properly dismissed the claims for lack of subject matter jurisdiction because the claims were preempted by federal bankruptcy law.Plaintiff, who had previously filed a bankruptcy petition in the United States Bankruptcy Court, brought this action asserting claims of vexatious litigation and violation of the Connecticut Unfair Trade Practices Act, Conn. Gen. Stat. 42-110a et seq. The trial court dismissed the claims. The Supreme Court affirmed, holding that Congress implicitly preempted state law actions by occupying the field of bankruptcy law and that, in the field of law, the federal interest is so dominant that federal law is assumed to preclude enforcement of state laws on the subject. View "Metcalf v. Fitzgerald" on Justia Law

In this dissolution of marriage action, the Supreme Court reversed the judgment of the appellate court reversing the decision of the trial court awarding appellate attorney's fees to Plaintiff under the bad faith exception to the American rule, holding that the trial court did not abuse its discretion in setting the amount of the fees.On appeal, Plaintiff argued that the appellate court did not accord the proper level of deference in concluding that the trial court's findings lacked sufficient specificity. The Supreme Court reversed and remanded the case to the appellate court with direction to affirm the trial court's award of attorney's fees, holding that the trial court acted within its discretion in awarding Plaintiff $30,000 in attorney's fees. View "Lederle v. Spivey" on Justia Law

In this medical negligence action, the Supreme Court affirmed the judgment of the trial court rendered in accordance with the court's granting of Defendants' motions to dismiss and for summary judgment, holding that the Court could not reach the merits of Plaintiff's claim that Conn. Gen. Stat. 52-190a is unconstitutional.Plaintiff brought this case against the State and numerous superior court judges, a psychiatrist and his employer, and business entities after his wife committed suicide. The trial court granted judgment for Defendants. On appeal, Plaintiff argued that section 52-190a, which requires a plaintiff to append a good faith certificate and supporting opinion letter to the complaint in cases of medical negligence, is unconstitutional. The Supreme Court affirmed, holding that because Plaintiff failed to challenge the trial court's threshold conclusions that his claims against Defendants were barred by, among other things, the doctrines of res judicata and collateral estoppel, this Court could not address the single substantive issue that Plaintiff raised and that the judgment of the trial court must be affirmed. View "Traylor v. State" on Justia Law

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