Justia Connecticut Supreme Court Opinion Summaries

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

The Supreme dismissed the writ of error filed by Appellant, who was suspended from the practice of law before the appellate court for a six-month period, holding that an additional order issued by the appellate court in 2018 clarifying the previous order did not violate the ex post facto clause in violation of the United States Constitution.In 2014, the appellate court issued its order suspending Appellant from practice and barring her from representing any client before the appellate court until she filed a motion for reinstatement and that motion had been granted. In 2018, the appellate issued issued an additional order clarifying that the 2014 order precluded Appellant from providing "legal services of any kind in connection with any" appellate court matter until she filed a motion for reinstatement and that motion had been granted. Appellant filed a writ of error, arguing, among other things, that the 2018 order was an unconstitutional ex post facto law because it retroactively prohibited her from engaging in certain conduct. The Supreme Court dismissed the writ of error, holding that the 2018 did not violate the ex post facto clause or Appellant's due process rights and that Appellant's claims of selective enforcement and discriminatory and retaliatory treatment were not reviewable by the Court. View "Cimmino v. Marcoccia" on Justia Law

The Supreme Court reversed in part the judgment of the appellate court affirming Defendant's conviction of two counts of assault in the first degree, holding that the evidence was insufficient to support Defendant's conviction.At issue in this appeal was what parameters should be used by the trier of fact to assess whether a defendant has inflicted serious physical injury in the form of serious disfigurement to be found guilty of assault in the first degree. Defendant argued that a forearm scar sustained by one victim was insufficient for the jury to find the serious physical injury necessary to support the charge of assault in the first degree. The Supreme Court agreed, holding (1) the victim's disfigurement was not of a magnitude that could be found to substantially detract from the victim's appearance, and therefore, the evidence was insufficient to meet the threshold for serious disfigurement; and (2) the State was not entitled to have Defendant's conviction modified. View "State v. Petion" on Justia Law

The Supreme Court affirmed the judgment of the trial court in this action seeking, inter alia, to enforce a foreign judgment, holding that a plaintiff who is neither a party to a mortgage nor an intended beneficiary of the mortgage has no standing to challenge the enforceability of that mortgage under the Connecticut Limited Liability Company Act, Conn. Gen. Stat. 34-130.The trial court entered judgment in part for Plaintiff as against the named defendant and entered judgment for defendant Manufacturers and Traders Trust Company (M&T Bank) and set aside certain fraudulent transfers and imposed constructive trusts on certain properties. The Supreme Court affirmed, holding (1) Plaintiff did not have standing to challenge the M&T Bank mortgage; (2) specified transfers between an owner of property and the limited liability companies of which he is either an officer or equity holder constitute fraudulent transfers under the Connecticut Uniform Fraudulent Transfer Act, Conn. Gen. Stat. 52-552e(a)(1) and (2) and 52-552f; and (3) the doctrine of reverse piercing of the corporate veil is a viable remedy in Connecticut, and the trial court properly applied it to the facts of this case. View "McKay v. Longman" on Justia Law

In this case alleging negligence against a physician, the Supreme Court recognized a third-party cause of action for negligent misreporting of sexually transmitted disease (STD) test results, holding that a physician who mistakenly informs a patient that he does not have an STD may be held liable in ordinary negligence to the patient's exclusive sexual partner for her resulting injuries when the physician knows that the patient sought testing and treatment for the express benefit of that partner.Plaintiff sued Defendant, a physician, alleging that Defendant had been negligent by misreporting the STD test results of her sexual partner. The trial court granted Defendant's motion to strike, concluding that Defendant did not owe a duty of care to Plaintiff. The Supreme Court reversed, holding that Defendant owed a duty of care to Plaintiff, even though she was not his patient. View "Doe v. Cochran" on Justia Law

In this foreclosure action, the Supreme Court held that Defendants John Sanzo and Maria Sanzo were not entitled to the homestead exemption, which is available when a creditor forecloses on a judgment lien but not on a consensual lien. See Conn. Gen. Stat. 52-352(b).Plaintiff, Rockstone Capital, LLC held judgment liens against Defendants. The parties agreed to a consensual lien in the form of a mortgage to secure the debt. Defendants defaulted on the mortgage payments, and Plaintiff sought to foreclose on the mortgage. Defendants invoked the homestead exemption. The trial court decided that the exemption should apply and rendered judgment for Plaintiff on the judgment liens, subject to the homestead exemption. The Appellate Court reversed, holding that the homestead exemption did not apply to a consensual lien such as a mortgage. The Supreme Court affirmed, holding that the Appellate Court properly found that the appeal was taken from a final judgment and the mortgage was a consensual lien. View "Rockstone Capital, LLC v. Sanzo" on Justia Law

The Supreme Court reversed Defendant's murder conviction and remanded the case for a new trial, holding that the trial court erred in denying Defendant's motion to suppress.Defendant was arrested for drug offenses and the murder of the victim. Five days after Defendant's rent was due for a second month the police searched his apartment without a warrant. The police discovered the victim's cell phone hidden in a bathroom wall. Defendant moved to suppress the evidence. The trial court denied the motion, concluding that Defendant did not have a subjective expectation of privacy in the apartment at the time of the search because the lease had expired and Defendant had failed to make rent payments and to secure his belongings in the apartment. The Supreme Court reversed, holding (1) under the facts of this case, Defendant established that the apartment was his home and neither his incarceration or his failure to pay rent five days after it was due divested him of his subjective expectation of privacy in his apartment; and (2) because the State did not argue that any error was harmless, the case is remanded for a new trial. View "State v. Jacques" on Justia Law

The Supreme Court reversed the judgment of the trial court granting summary judgment in favor of Defendant on the grounds that the Federal Railroad Safety Act of 1970, 49 U.S.C. 20101 et seq., preempted Plaintiff's negligence claims, holding that Defendant failed to meet its burden of demonstrating that Plaintiff's claim was preempted under the railroad act.Plaintiff, individually and as executrix of the estate of her late husband (decedent), filed this action against Defendant, Metro-North Commuter Railroad Company, claiming that the decedent's injuries and death were proximately caused by the negligence of Defendant when it violated practices and customs with respect to track selection. Defendant filed a motion for summary judgment, arguing that the subject matter of Plaintiff's claim was covered by federal regulations addressing speed and track classification. The trial court granted summary judgment for Defendant, concluding that, to the extent that Plaintiff's claim was viewed as relating to rail safety, it was barred by the railroad act. The Supreme Court reversed after noting the narrow preemption provision in the railroad act, the acknowledgement that the federal regulations provide the minimum safety standards, and the lack of a regulatory provision expressly addressing track selection, Plaintiff's claim was not preempted under the railroad act. View "Murphy v. Darien" on Justia Law