Justia Connecticut Supreme Court Opinion Summaries

The trial court improperly determined that evidence of the victim’s convictions for crimes of violence is inadmissible as a matter of law, but the error was harmless.Defendant was charged with assault in the second degree by means of a dangerous instrument. Prior to trial, the State filed motion in limine requesting that the trial court preclude evidence of the victim’s criminal convictions, which the State anticipated Defendant would attempt to submit to support his claim of self-defense. The trial court granted the motion, concluding that evidence of the convictions would not be admissible as a matter of law because they occurred subsequent to the charged conduct. The jury rejected Defendant’s claim of self-defense and found Defendant guilty as charged. The Appellate Court affirmed, holding that the trial court abused its discretion by excluding evidence of the victim’s subsequent convictions but that the error was harmless. The Supreme Court affirmed, holding that Defendant did not meet his burden to prove that the exclusion of evidence of the victim’s subsequent convictions was harmful error. View "State v. Jordan" on Justia Law

Exercising jurisdiction over Defendant-insurer under the circumstances of this case was permitted by Connectictut’s corporate long arm statute, Conn. Gen. Stat. 33-929(f)(1), and comported with the due process clause of the Fourteenth Amendment.Defendant issued an automobile insurance policy covering a vehicle driven by Insured. The policy was written in New York at Defendant’s principal place of business, and Defendant did not direct or participate in any business transactions in Connecticut at the time. The coverage territory of the policy included Connecticut. Insured’s vehicle later collided with a vehicle occupied by Plaintiffs. A judgment was rendered against Insured in favor of Plaintiffs. Defendant failed to defend Insured or to indemnify him for the judgment rendered against him. Plaintiffs then brought this action against Defendant. Defendant moved to dismiss the action for lack of personal jurisdiction. The trial court granted the motion to dismiss. The Supreme Court reversed, holding that Defendant’s agreement to defend and indemnify Insured established personal jurisdiction under the long arm statute and that subjecting Defendant to the jurisdiction of this state comported with the due process clause of the Fourteenth Amendment. View "Samelko v. Kingstone Insurance Co." on Justia Law

Exercising jurisdiction over Defendant-insurer under the circumstances of this case was permitted by Connectictut’s corporate long arm statute, Conn. Gen. Stat. 33-929(f)(1), and comported with the due process clause of the Fourteenth Amendment.Defendant issued an automobile insurance policy covering a vehicle driven by Insured. The policy was written in New York at Defendant’s principal place of business, and Defendant did not direct or participate in any business transactions in Connecticut at the time. The coverage territory of the policy included Connecticut. Insured’s vehicle later collided with a vehicle occupied by Plaintiffs. A judgment was rendered against Insured in favor of Plaintiffs. Defendant failed to defend Insured or to indemnify him for the judgment rendered against him. Plaintiffs then brought this action against Defendant. Defendant moved to dismiss the action for lack of personal jurisdiction. The trial court granted the motion to dismiss. The Supreme Court reversed, holding that Defendant’s agreement to defend and indemnify Insured established personal jurisdiction under the long arm statute and that subjecting Defendant to the jurisdiction of this state comported with the due process clause of the Fourteenth Amendment. View "Samelko v. Kingstone Insurance Co." on Justia Law

In this habeas corpus proceeding, the Supreme Court held that the habeas court properly concluded that Petitioner was entitled to a new trial because counsel in his murder case rendered ineffective assistance.On appeal by the Commissioner of Correction from the habeas court’s decision, the Supreme Court held that the habeas court properly found (1) counsel’s failure to obtain readily available evidence that he should have known was potentially critical to Petitioner’s alibi defense was constitutionally inexcusable; and (2) counsel’s inadequate performance resulted in prejudice to Petitioner sufficient to undermine confidence in the outcome of Petitioner’s criminal trial. View "Skakel v. Commissioner of Correction" on Justia Law

The Supreme Court reversed the judgment of the trial court granting an application by five individual electors of the Town of Fairfield (collectively, Plaintiffs) for a writ of mandamus compelling a special election for a vacant seat on the Board of Selectmen.On appeal, the Town and its Board (collectively, Defendants) argued that the trial court improperly issued the writ of mandamus. Specifically, Defendants argued that article VI, 6.3(B) of the Fairfield Town Charter, which does not provide for a special election when the Board has acted to fill a vacancy within thirty days, was controlling over Conn. Gen. Stat. 9-222, which provides for the possibility of a petition for a special election to fill a vacancy on the Board even after the Board has acted. The Supreme Court agreed, holding (1) the charter provision controlled the method by which to fill the vacancy on the Board; and (2) because the Board timely designated a new selectman, the provision of the charter directing resort to Conn. Gen. Stat. chapter 146, which could have required a special election pursuant to section 9-222, was not triggered. View "Cook-Littman v. Board of Selectmen" on Justia Law

The Supreme Court affirmed the decision of the trial court rendering judgment in favor of Plaintiff on its claim of unjust enrichment.On appeal, Defendant argued that Plaintiff’s unjust enrichment claim was barred by collateral estoppel, that Plaintiff’s recovery was precluded by law and the terms of an agreement between the parties, the trial court’s jury instructions were improper, and the trial court erred in excluding certain evidence. In affirming, the Court held that many of Defendant’s arguments were unpreserved, inadequately briefed, or both, and that Defendant was not entitled to relief on any of his assignments of error. View "MacDermid, Inc. v. Leonetti" on Justia Law

The Supreme Court reversed the judgment of the Appellate Court affirming the judgment of the trial court in favor of Plaintiff against Defendants, Joan Frank and George Frank, holding that there was no final judgment as to George, and therefore, the Appellate Court lacked jurisdiction over Defendants’ joint appeal.Plaintiff filed this action alleging common-law enforcement of a foreign default judgment and seeking recovery under theories of breach of contract and quantum meruit. The trial court found in favor of Plaintiff on count one against George and on count two against Joan. The Appellate Court affirmed the trial court’s judgment, rejecting Defendants’ claims on appeal on the merits. The Supreme Court reversed, holding that the trial court’s failure to dispose of either the contract count or the quantum meruit count as to George resulted in the lack of a final judgment, and therefore, the Appellate Court should have dismissed Defendants’ joint appeal. View "Meribear Productions, Inc. v. Frank" on Justia Law

The Supreme Court affirmed the judgment of the trial court finding that Defendants had trespassed on property that Plaintiff owned.When Plaintiff commenced this action alleging trespass Defendants claimed that Plaintiff could not establish its ownership or possessory interest in the property on which Defendants were building. The trial court ruled in favor of Plaintiff and issued a permanent mandatory injunction ordering Defendants to remove structures from Plaintiff’s property that were not authorized by the permits issued to Defendants. The Supreme Court affirmed, holding (1) there was sufficient evidence to support the trial court’s finding that Plaintiff owned the subject property, and (2) the scope of the trial court’s injunctive relief was not overly broad. View "FirstLight Hydro Generating Co. v. Stewart" on Justia Law

A court may look to the evidence presented at trial when determining if a defendant’s conviction violated the constitution prohibition against double jeopardy.Defendant appealed his convictions of assault of public safety personnel and interfering with an officer, arguing that the two convictions constituted a double jeopardy violation. To resolve Defendant’s claim, the Appellate Court reviewed evidence presented at trial and concluded that the two crimes did not stem from the same conduct. Consequently, the Appellate Court concluded that Defendant did not satisfy the requirements to establish a double jeopardy violation in the context of a single trial. The Supreme Court affirmed, holding (1) the Appellate Court properly reviewed the evidence to determine that the offenses in question did not arise from the same act or transaction; and (2) therefore, Defendant’s conviction did not violate double jeopardy. View "State v. Porter" on Justia Law

The Supreme Court affirmed the judgment of the trial court dismissing Plaintiff’s appeal from the decision of the Town of Lyme and its Board of Selectmen (collectively, Defendants) determining the lost or uncertain boundaries of the westerly end of Brockway Ferry Road pursuant to Conn. Gen. Stat. 13a-39.On appeal, Plaintiff challenged the subject matter jurisdiction of the Board and the trial court and argued that the trial court’s determination of the highway’s width was clearly erroneous. In affirming, the Supreme Court held (1) the trial court correctly determined that the Board had jurisdiction to define the highway’s boundaries under section 13a-39 despite the absence of a prior judicial determination regarding the highway’s legal status; (2) the proceedings before the Board complied with section 13a-39, and thus the trial court was not divested of subject matter jurisdiction; and (3) the trial court’s finding of the highway’s boundaries was not clearly erroneous. View "Marchesi v. Board of Selectmen of the Town of Lyme" on Justia Law