Justia Connecticut Supreme Court Opinion Summaries

The Supreme Court reversed the judgment of the trial court granting summary judgment in favor of Defendant, Southeastern Connecticut Water Authority, on the basis of a rule (Rule) promulgated by Defendant immunizing itself from liability for failures or deficiencies in its supply of water to customers, holding that there was no explicit authorization in the special act creating Defendant that authorized Defendant to promulgate such a rule.Defendant was created in 1967 by a special act of the General Assembly. On the basis of the authority purportedly granted to it by a provision of the special act, Defendant adopted the Rule at issue in this case. Plaintiff later commenced this action seeking damages on the basis of a loss of water service at a hotel operated by Plaintiff. Defendant moved for summary judgment, arguing (1) the Rule immunized it from liability, and (2) the claim was barred by the common-law economic loss doctrine. The trial court rendered summary judgment for Defendant based on the Rule. The Supreme Court reversed and remanded the case, holding that Defendant lacked authority to promulgate a rule that immunized it from liability for disruptions to water service. View "Raspberry Junction Holding, LLC v. Southeastern Connecticut Water Authority" on Justia Law

The Supreme Court reversed the decision of the Compensation Review Board affirming the decision of the Workers' Compensation Commissioner concluding that Plaintiff was not an employee of Intervale Group, LLC for purposes of the Workers' Compensation Act, holding that Plaintiff qualified as Intervale's employee for purposes of the Act and, therefore, was eligible for concurrent compensation benefits pursuant to Conn. Gen. Stat. 31-310.Plaintiff was the sole member of Intervale, a single-member limited liability company. Plaintiff was employed part-time by the City of Stamford. After he was injured while working for the City, Plaintiff sought compensation based on the earnings that he received from both the City and Intervale, claiming that he was concurrently employed by Intervale. The City transferred the concurrent compensation obligation to the Second Injury Fund, which denied the claim for benefits on the ground that Plaintiff was not Intervale's employee. The Commissioner concluded that Plaintiff was not an employee of Intervale, and the Board affirmed. The Supreme Court reversed, holding that because Plaintiff provided services to Intervale and was subject to the hazards of Intervale's business, Plaintiff was Intervale's employee for purposes of the Act. View "Gould v. Stamford" on Justia Law

The Supreme Court reversed the judgment of the Appellate Court affirming Defendant's conviction, holding that Defendant's statements during interrogation did not meet the standard set forth in Davis v. United States, 512 U.S. 452, 459-60 (1994), so as to require suppression but that a more protective prophylactic rule set forth in this opinion is required under the Connecticut constitution to adequately safeguard the right against self-incrimination.Defendant was convicted of three counts of risk of injury to a child. On appeal, Defendant challenged the denial of his motion to suppress certain statements he made during interrogation, arguing that the statements had been elicited after he invoked his right to have counsel present. The Appellate Court affirmed, holding that Defendant's references to counsel would not have been understood by a reasonable police officer as an expression of a present desire to consult with counsel. The Supreme Court reversed, holding (1) Defendant's statements during the interrogation did not constitute an invocation of his right to counsel under Davis; (2) however, the state Constitution requires that police officers clarify an ambiguous request for counsel before they can continue the interrogation; and (3) because no such clarification was elicited in this case, and the failure to do so was harmful, Defendant was entitled to a new trial. View "State v. Purcell" on Justia Law

The Supreme Court affirmed the judgments of the trial court granting Defendant's motions to suppress all cell site location information (CSLI) obtained by the State as a result of three ex parte orders that had been granted pursuant to Conn. Gen. Stat. 54-47aa, holding that because the State obtained did not obtain Defendant's historical CSLI based on a warrant supported by reasonable cause, the records were obtained in violation of Defendant's Fourth Amendment rights.The State obtained the CSLI at issue solely on the basis of a reasonable and articulable suspicion. The State conceded that it obtained the CSLI in violation of section 54-47aa. The trial court determined that suppression of both the historical and the prospective CSLI was the appropriate remedy. The Supreme Court affirmed, holding (1) the trial court properly granted Defendant's motions to suppress the CSLI records because the records were obtained illegally and because suppression was the appropriate remedy as to the illegally obtained records; and (2) the trial court properly determined that suppression of those records also required that Defendant's statement and potential testimony be suppressed. View "State v. Brown" on Justia Law

The Supreme Court reversed the judgment of the trial court denying Defendant's motion to suppress evidence discovered by the police during the forcible detention of Defendant, holding that Defendant's detention violated his Fourth Amendment rights under Navarette v. California, 572 U.S. 393 (2014).Defendant was detained pursuant to Terry v. Ohio, 392 U.S. 1 (1968) on the basis of an anonymous telephone tip regarding "a young man that has a handgun." After Defendant was detained, the police saw him drop an object in a garbage can. A subsequent search revealed that the object was a handgun. Defendant was charged with criminal possession of a pistol and carrying a pistol without a permit. Defendant filed a motion to suppress, arguing that his detention was unconstitutional because the anonymous tip did not give rise to a reasonable suspicion that he was engaged in, or was about to be engaged in, criminal activity. Therefore, Defendant argued that the handgun was tainted as the result of his unlawful seizure. The trial court denied the motion to suppress. The Supreme Court reversed, holding that the anonymous telephone call did not give rise to a reasonable suspicion that Defendant was in possession of a handgun, justifying an investigative Terry stop. View "State v. Davis" on Justia Law

The Supreme Court affirmed the judgment of the Appellate Court concluding that the improper exclusion of P's testimony during the underlying criminal proceedings was not harmless, holding that the testimony was necessary for the jury to assess the complainant's credibility, and therefore, the exclusion of P's testimony was not harmless.Defendant was charged with sexual assault in the second degree and two counts of risk of injury to a child. The trial court precluded Defendant from calling P, the complainant's longtime boyfriend, as a witness regarding his observations of certain aspects of the complainant's behavior that the State's expert witness had testified were commonly exhibited by child victims of sexual assault. The Appellate Court reversed, holding that P's testimony was improperly excluded because it was relevant to the issue of whether the complainant had exhibited behaviors associated with some sexual assault victims, which had a clear and direct bearing on the central issue in this case - whether the complainant had been sexually assaulted by Defendant. The Supreme Court affirmed, holding that the improper exclusion of P's testimony was not harmless. View "State v. Fernando V." on Justia Law

In this action brought by the administrators of the estates of nine people killed in the massacre at Sandy Hook Elementary School, the Supreme Court held that the trial court properly determined that, although the trial court properly struck most of Plaintiffs’ claims against various manufacturers, distributors and sellers of the Bushmaster XM15-E2S semiautomatic rifle, the Protection of Lawful Commerce in Arms Act (PLCAA), 15 U.S.C. 7901 through 7903, did not bar Plaintiffs’ claims that Defendants violated the Connecticut Unfair Trade Practices Act (CUPTA), Conn. Gen. Stat. 42-110a et seq., by marketing the firearm to civilians for criminal purposes and that those wrongful marketing tactics contributed to the massacre.Adam Lanza carried out the massacre using a XM15-E2S. The Supreme Court affirmed the trial court’s judgment that most of Plaintiffs’ claims were precluded by established Connecticut law and/or PLCAA. However, as to Plaintiffs’ claims that Defendants knowingly marketed, advertised, and promoted the XM15-E2S for civilians to use to carry out offensive, military style combat missions, the Supreme Court held that Plaintiffs pleaded allegations sufficient to survive a motion to strike because (1) PLCAA does not bar Plaintiffs’ wrongful marketing claims; and (2) to the extent that it prohibits the unethical advertising of dangerous products for illegal purposes, CUTPA qualifies as a predicate statute. View "Soto v. Bushmaster Firearms International, LLC" on Justia Law

The Supreme Court affirmed the judgment of the Appellate Court affirming Defendant’s judgment of conviction, holding that the evidence was sufficient to support Defendant’s conviction for attempt to commit murder under the substantial step provision of Conn. Gen. Stat. 53a-49(a)(2) because the determination of what constitutes a substantial step focuses on what the actor has already done rather than on what the actor has left to do to complete the substantive crime.The Appellate Court concluded that there was sufficient evidence to sustain Defendant’s conviction of attempted murder after construing section 53a-49(a)(2) to require the substantial step inquiry to focus on what the actor has already done rather than what remains to be done. The Supreme Court affirmed, holding that there was ample evidence from which a jury could have determined beyond a reasonable doubt that Defendant took a substantial step to murder the intended victim. View "State v. Daniel B." 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 on illegal sentence, holding that the Appellate Court’s thorough and well reasoned opinion fully addressed Defendant’s question certified to the Supreme Court.The Supreme Court granted Defendant’s petition for certification to appeal, limited to the question of whether the Appellate Court properly concluded that Defendant’s sentence was not illegal, did not violate the Double Jeopardy Clause, and did not run contrary to legislative intent. The Supreme Court adopted the Appellate Court’s opinion as the proper statement of the issues and the applicable law concerning those issues and affirmed. View "State v. Henderson" on Justia Law

The Supreme Court affirmed the judgment of the Appellate Court reversing the judgments of the trial court denying the petitions filed by the maternal grandmother (Petitioner) for termination of Father's parental rights with respect to his three minor children, holding that the trial court applied an incorrect legal test to determine that Petitioner had failed to prove the lack of an ongoing parent-child relationship.Specifically, the Court held (1) the trial court erred in concluding that, under the facts of this case, it was required to depart from the usual test to determine whether a petitioner has established a lack of an ongoing parent-child relationship; and (2) the trial court’s finding that Petitioner failed to prove that allowing further time to develop a parent-child relationship would be detrimental to the best interests of the children was clearly erroneous. View "In re Jacob W." on Justia Law