Justia Connecticut Supreme Court Opinion Summaries

The plaintiff, an employee, alleged that her employer created a hostile work environment through the actions of her immediate superior, who made racially discriminatory comments. The plaintiff reported these incidents to the employer's human resources department, which conducted an investigation and issued a one-day suspension to the superior. Despite the employer's actions, the plaintiff felt unable to continue working under the superior and transferred to another division.The Commission on Human Rights and Opportunities determined that the employer was not vicariously liable for the hostile work environment because the superior did not have the authority to take tangible employment actions against the plaintiff. The trial court upheld this decision, and the Appellate Court affirmed, applying the definition of "supervisor" from the U.S. Supreme Court's decision in Vance v. Ball State University, which limits the term to those who can take tangible employment actions.The Connecticut Supreme Court reviewed the case and affirmed the Appellate Court's decision. The court held that the Vance definition of "supervisor" applies to claims under the Connecticut Fair Employment Practices Act. Since the superior did not have the authority to take tangible employment actions against the plaintiff, the employer could not be held vicariously liable for the creation of a hostile work environment. The court emphasized the importance of consistency with federal law in interpreting state employment discrimination statutes. View "O'Reggio v. Commission on Human Rights & Opportunities" on Justia Law

The case involves two competing slates of candidates seeking to appear on the ballot for the March 5, 2024, primary election for the Democratic Town Committee for the seventh district of Hartford. The plaintiffs, members of one slate, challenged the validity of a petition sheet submitted by the defendants, members of the other slate, on the grounds that one signature was not signed by the named individual but by his son under a purported power of attorney. The defendants counterclaimed, arguing that five petition sheets submitted by the plaintiffs should be invalidated for not including a written tally of the number of verified signatures as required by statute.The Superior Court in the judicial district of Hartford found that the signature in question on the defendants' petition sheet was invalid because there was no evidence that the son had a valid power of attorney or that it included the authority to sign political petitions. Consequently, the court rejected the entire petition sheet, reducing the defendants' valid signatures below the required threshold, and ordered their removal from the ballot. The court also found that one of the plaintiffs' petition sheets contained a forged signature and rejected it, but it ruled that the other five challenged sheets substantially complied with the statutory requirements despite lacking the signature tally.The Connecticut Supreme Court reviewed the case and agreed with the trial court that the signature on the defendants' petition sheet was invalid and that the entire sheet must be rejected. The court held that the statutory language was clear in requiring the rejection of any petition page with procedural violations, including false attestations. However, the Supreme Court disagreed with the trial court's finding of substantial compliance for the plaintiffs' five petition sheets lacking the required tally. The court held that these sheets must also be rejected, which would reduce the plaintiffs' valid signatures below the required threshold, disqualifying both slates from the primary ballot.The judgment was reversed in part and affirmed in part, with the case remanded for further proceedings to determine the conduct of the primary election with both slates disqualified. View "Airey v. Feliciano" on Justia Law

The plaintiffs, parents of minor children, challenged a public act that eliminated the religious exemption from vaccination requirements for school enrollment. They argued that the act violated their constitutional rights to free exercise of religion, equal protection, and a free public education, as well as their statutory rights under Connecticut law. The defendants, state and municipal officials, moved to dismiss the case on the grounds of sovereign immunity.The trial court denied the defendants' motions to dismiss, concluding that the plaintiffs' constitutional claims satisfied the substantial claim exception to sovereign immunity, and their statutory claim under Connecticut law satisfied the statutory waiver exception. The defendants appealed this decision.The Connecticut Supreme Court reviewed the case and determined that the trial court must assess the legal sufficiency of the plaintiffs' allegations to determine whether they have asserted a substantial claim of a constitutional violation. The court concluded that the plaintiffs' constitutional claims failed as a matter of law. The act was deemed a neutral law of general applicability, rationally related to the state's interest in protecting public health. The court also found that the act did not violate the plaintiffs' right to a free public education, as it imposed a reasonable vaccination requirement.However, the court agreed with the trial court that the plaintiffs' statutory free exercise claim under Connecticut law satisfied the statutory waiver exception to sovereign immunity. The court found that the scope of the waiver extended to free exercise challenges to the enforcement of legislation and that applying the statute to the public act did not violate any constitutional principles.The Connecticut Supreme Court reversed the trial court's decision in part, directing the dismissal of the constitutional claims, but affirmed the decision regarding the statutory claim, allowing it to proceed. View "Spillane v. Lamont" on Justia Law

The plaintiff, a property owner, was ordered by the Pine Orchard Association's zoning enforcement officer to cease and desist from renting his property on a short-term basis. The plaintiff appealed to the Zoning Board of Appeals of the Pine Orchard Association, which upheld the cease and desist order. The plaintiff then appealed to the Superior Court, which reversed the board's decision, concluding that the plaintiff's use of the property for short-term rentals was permitted under the 1994 zoning regulations.The defendants, including the zoning board and intervening neighbors, appealed to the Appellate Court. The Appellate Court affirmed in part and reversed in part the trial court's judgment, agreeing that the 1994 regulations permitted short-term rentals but remanding the case for a factual determination on whether the plaintiff had established a lawful, nonconforming use of the property.The Supreme Court of Connecticut reviewed the case and affirmed the Appellate Court's decision. The court held that the language of the 1994 zoning regulations, which permitted the use of a property as a single-family dwelling, was ambiguous. The court concluded that the short-term rental of a single-family dwelling constituted a permissible use under those regulations. The court reasoned that the terms "home" and "residence" could reasonably be interpreted to mean a structure used as a house or dwelling, without any temporal occupation requirement. The court also noted that the regulations did not differentiate between long-term and short-term rentals, and thus, short-term rentals were permitted. View "Wihbey v. Zoning Board of Appeals" on Justia Law

The defendant was convicted of assault in the first degree after an altercation with a friend, during which he stabbed the friend multiple times. Following the incident, the defendant sought medical treatment at a hospital for injuries sustained during the fight. While at the hospital, he was questioned by several police officers without being advised of his Miranda rights. The defendant moved to suppress the statements made during these interactions, arguing that he was in custody and subject to interrogation without proper Miranda warnings.The trial court denied the motion to suppress, finding that the defendant was not in custody during the hospital questioning. The court noted that the defendant was not handcuffed, was coherent despite his intoxication, and was not subjected to prolonged or aggressive questioning. The defendant was subsequently found guilty of assault in the first degree and sentenced to ten years of incarceration, suspended after seven years, with five years of probation.The Appellate Court reversed the conviction, concluding that the defendant was in custody for Miranda purposes when questioned by the police at the hospital. The court reasoned that the presence of multiple officers, the defendant's physical condition, and the nature of the questioning created a custodial environment. The Appellate Court held that the trial court should have suppressed the statements and remanded the case for a new trial.The Connecticut Supreme Court reviewed the case and reversed the Appellate Court's decision. The Supreme Court held that the defendant was not in custody during the hospital interactions. The court emphasized that the defendant was not physically restrained by the police, the questioning was not aggressive or prolonged, and the defendant was informed that he was free to leave for police purposes. The court concluded that a reasonable person in the defendant's position would not have felt a restraint on freedom of movement to the degree associated with a formal arrest. Therefore, the police were not required to administer Miranda warnings, and the trial court's denial of the motion to suppress was affirmed. View "State v. Garrison" on Justia Law

The defendant was convicted of home invasion and first-degree burglary after breaking into an apartment while armed with a Crosman Vigilante air gun. The air gun was loaded with pellets but lacked a CO2 cartridge, and the chamber for the cartridge was sealed with duct tape. The defendant was identified by one of the residents after a physical altercation and was later arrested. The state needed to prove that the defendant was armed with a "deadly weapon or dangerous instrument" to secure a conviction.The Superior Court in the judicial district of Danbury denied the defendant's motion for a judgment of acquittal, which argued that the air gun was not operable and thus not a deadly weapon. The jury was instructed that a deadly weapon is any weapon from which a shot may be discharged, whether loaded or unloaded, and found the defendant guilty of home invasion and first-degree burglary. The trial court rendered judgment consistent with the verdict and sentenced the defendant to sixteen years of incarceration, suspended after twelve years, and five years of probation.The Connecticut Supreme Court reviewed the case and determined that the question of whether the air gun was a deadly weapon was subject to plenary review. The court concluded that the air gun, which required significant effort to be made operable due to the duct tape sealing the CO2 chamber, was not a weapon from which a shot could be readily discharged. The court held that the trial court's instruction to the jury was legally erroneous, as it did not convey the immediacy requirement implied by the statute defining a deadly weapon. Consequently, the defendant's conviction could not stand, and the judgment was reversed, with the case remanded for a new trial. View "State v. Carter" on Justia Law

The defendant was convicted of assaulting public safety personnel and interfering with an officer after injuring a police officer during the execution of an arrest warrant. The warrant included charges of assault in the first degree and criminal possession of a firearm. The officers, part of a multi-agency task force, used significant force to enter the defendant's residence, where the defendant resisted arrest, leading to the officer's injuries.The trial court admitted testimony about the felony charges in the arrest warrant and identified the task force as the "Violent Fugitive Task Force." The defendant objected, arguing that this evidence was unduly prejudicial. The trial court overruled the objections, finding the evidence relevant to explain the officers' conduct and the reasonableness of their use of force. The jury found the defendant guilty, and the trial court sentenced him to eight years of incarceration followed by two years of special parole.The Appellate Court affirmed the trial court's decision, concluding that the evidence was relevant to show the officers were acting in the performance of their duties and that any prejudice was mitigated by limiting instructions. The defendant appealed to the Connecticut Supreme Court, arguing that the evidence was unduly prejudicial.The Connecticut Supreme Court held that the trial court did not abuse its discretion in admitting the names of the felony charges, as they were relevant to the officers' use of force and the performance of their duties. However, the Court found that the name "Violent Fugitive Task Force" had no probative value and was unfairly prejudicial. Despite this, the Court concluded that the error was harmless given the strength of the state's case and the defense's focus on causation rather than the officers' conduct. The judgment of the Appellate Court was affirmed. View "State v. Delacruz-Gomez" on Justia Law

The plaintiff, a company that constructs and operates fuel cells, sought municipal property tax exemptions for its fuel cell modules and related equipment installed on the Pfizer campus. The property primarily provided electricity and converted waste heat into thermal energy. The plaintiff applied for tax exemptions under Connecticut General Statutes § 12-81 (57), which exempts class I renewable energy sources from taxation. The defendant, the town of Groton, denied the applications, classifying the property as a cogeneration system under § 12-81 (63), which allows but does not require municipalities to exempt such systems from taxation.The Superior Court granted partial summary judgment to the plaintiff, ruling that the property was exempt from taxation for the years 2017 through 2019 under § 12-81 (57). The court found that the property, which included fuel cells with a heat recovery steam generator (HRSG), fell within the definition of a class I renewable energy source. For the 2016 tax year, the court held a trial and determined that the property was not completely manufactured by October 1, 2016, and thus was exempt under § 12-81 (50) as "goods in the process of manufacture." The court also ruled that the plaintiff was not required to file a personal property declaration for the exempt property, and the penalties imposed by the defendant for failing to file such a declaration were improper.The Connecticut Supreme Court upheld the trial court's rulings. It agreed that the property was exempt from taxation under § 12-81 (57) for the years 2017 through 2019, as the statute specifically exempts class I renewable energy sources, including fuel cells. The court also affirmed that the property was exempt for the 2016 tax year under § 12-81 (50) as it was still in the process of manufacture. Finally, the court held that the plaintiff was not required to file a personal property declaration for the exempt property, and the penalties for failing to do so were not permitted. View "FuelCell Energy, Inc. v. Groton" on Justia Law

The plaintiffs, former residents of a federally subsidized housing complex, alleged that the defendants, the complex's owner and management company, failed to maintain the property in a safe and habitable condition. They claimed the defendants delayed inspections, concealed hazards, and violated housing laws. The plaintiffs sought class certification for all residents from 2004 to 2019, citing issues like a 2019 sewage backup and systemic neglect.The Superior Court in Hartford, transferred to the Complex Litigation Docket, denied the motion for class certification. The court found that the proposed class did not meet the predominance and superiority requirements under Practice Book § 9-8 (3). It reasoned that determining whether each unit was uninhabitable required individualized proof, making a class action unsuitable. The court noted that while some claims might support class certification for specific events, the broad class definition over many years was too extensive.The Connecticut Supreme Court reviewed the case and affirmed the lower court's decision. The court held that the proposed class was too broad and lacked generalized evidence for the entire period. It emphasized that the trial court had no obligation to redefine the class sua sponte. The plaintiffs did not request a narrower class definition, and the trial court was not required to do so on its own. The court concluded that the trial court did not abuse its discretion in denying class certification. View "Collier v. Adar Hartford Realty, LLC" on Justia Law

In September 1995, the body of a young woman, later identified as the defendant's daughter, was found in New Britain, Connecticut. The body was wrapped in trash bags and sleeping bags, and the police collected hairs and palm prints from the scene. Around the same time, the defendant told a family member he was leaving the country for a job and that his wife and daughter had already left. In October 1995, the body of the defendant's wife was found in Massachusetts. Both were reported missing later that year. In 2014, law enforcement collected DNA and prints from the defendant, linking him to the crime scene. The defendant was convicted of his wife's murder in Massachusetts and later charged with his daughter's murder in Connecticut.The trial court denied the defendant's motion to dismiss for lack of territorial jurisdiction, applying a presumption that the murder occurred where the body was found. The court also denied the defendant's request for a jury instruction that his palm prints on the trash bags could not establish his connection to the crime unless they were impressed at the time of the crime. The jury found the defendant guilty, and he was sentenced to sixty years in prison.The Connecticut Supreme Court affirmed the trial court's decision. The court held that the presumption that a murder occurred where the body was found was valid and did not violate due process. The court also found sufficient evidence to establish the defendant's identity as the murderer, including consciousness of guilt evidence and physical evidence linking him to the crime scene. The court further held that the trial court properly declined to provide the requested jury instruction on fingerprint evidence, as the palm prints were not the only or principal evidence against the defendant. View "State v. Honsch" on Justia Law