Justia Connecticut Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the trial court convicting Defendant of a single violation of Conn. Gen. Stat. 53-247, a provision that criminalizes a broad range of acts of cruelty to animals, stemming from Defendant’s shooting of his neighbor’s cat with a BB gun. The court held (1) the trial court properly concluded that the clause of section 53-247(a) applicable to Defendant’s conviction, which bars a person from “unjustifiably injur[ing]” an animal, requires only a general intent to engage in the behavior causing the injury; (2) the phrase “justifiably injures” in section 53-247(a) is not unconstitutionally vague; and (3) the evidence was sufficient to support Defendant’s conviction. View "State v. Josephs" on Justia Law

At issue was whether the trial court erred in determining that Plaintiff proved the imminent harm to identifiable persons exception to the defense of governmental immunity with respect to injuries he sustained when other students ran with a pair of scissors in the auditorium of his school.Plaintiff filed suit against the City of New Haven, the Board of Education of the City of New Haven, and the Superintendent of New Haven Public Schools seeking damages for, inter alia, negligent supervision of students. The trial court found in favor of Plaintiff on his negligent supervision claim. The Supreme Court reversed in part the judgment of the trial court, holding (1) Plaintiff failed to prove that Defendants’ conduct subjected an identifiable person to imminent harm; and (2) the trial court implicitly granted Defendants’ request to amend their answer to plead governmental immunity as a special defense. View "Martinez v. New Haven" on Justia Law

At issue in this appeal was the contours of the proof necessary for an employee to establish an employer’s subjective intent to create a dangerous situation with a “substantial certainty of injury” to the employee for purposes of avoiding application of the exclusive remedy provision of the Workers’ Compensation Act. The Supreme Court held that, under the circumstances of this case and in the absence of any evidence demonstrating the hallmarks typical of employer misconduct, Plaintiff failed to establish a genuine issue of material fact with respect to whether Defendants subjectively believed that Plaintiff’s injuries from the use of a particular excavator were substantially certain to occur. View "Lucenti v. Laviero" on Justia Law

The trial court did not err in determining that Plaintiffs failed to establish that the state’s educational offerings are not minimally adequate under Conn. Const. art. VIII, 1.Plaintiffs brought this action seeking, inter alia, a declaratory judgment that various state officials and members of the State Board of Education failed to provide “suitable and substantially equal educational opportunities” in violation of Conn. Const. art. VIII, 1 and Conn. Const. art. I, 1 and 20, as amended by articles five and twenty-one of the amendments. The trial court concluded that the state’s educational policies and spending practices violate article eighth, section one and rejected Plaintiffs’ remaining arguments. The Supreme Court affirmed in part and reversed in part, holding that Plaintiffs failed to establish that Defendants violated Plaintiffs’ rights under article eighth, section one and article first, sections one and twenty. View "Connecticut Coalition for Justice in Education, Inc. v. Rell" on Justia Law

A duty of confidentiality arises from the physician-patient relationship, and unauthorized disclosure of confidential information obtained in the course of that relationship for the purpose of treatment gives rise to a cause of action sounding in tort against the health care provider, unless the disclosure is otherwise allowed by law.The Supreme Court reversed the judgment of the trial court entering judgment in favor of Defendant, Avery Center for Obstetrics and Gynecology, P.C., on Plaintiff’s claims of negligence and negligent infliction of emotional distress. On appeal, Plaintiff argued that the trial court erred in granting summary judgment in favor of Defendant on these counts because the court improperly concluded that Defendant, as a health care provider, owed Plaintiff no duty of confidentiality. The Supreme Court agreed, holding that there was a genuine issue of material fact as to whether Defendant violated the duty of confidentiality under the facts of this case. View "Byrne v. Avery Center for Obstetrics & Gynecology, P.C." on Justia Law

Termination of parental rights pursuant to Conn. Gen. Stat. 17a-112(j)(3)(C) may not be based upon predictive harm.Parents appealed from the judgments of the trial court terminating their parental rights as to their two daughters after finding acts of parental commission or omission that denied the children the care necessary for the children’s physical or emotional well-being under section 17a-112(j)(3)(C). On appeal, Parental argued that the trial court improperly terminated their parental rights based on a finding of a predictive harm. The Supreme Court agreed but held that the court properly found that the statute was proven on the basis that one of the daughters had been harmed by Parents’s postremoval acts of parental commission or omission. Accordingly, the Supreme Court affirmed the judgment of the trial court. View "In re Egypt E." on Justia Law

The Supreme Court affirmed the judgment of the trial court granting Ruth Cohen’s motion to modify a modification order modifying the alimony provision of the divorce decree dissolving the marriage of Franklin and Ruth Cohen. Franklin moved to modify the alimony provision on the ground that his income had declined significantly. Ruth later moved to modify the modification order on the ground that Franklin’s income had substantially increased. The trial court granted the motion. Franklin appealed, raising four allegations of error. The Supreme Court affirmed, holding that Franklin’s allegations of error were unavailing. View "Cohen v. Cohen" on Justia Law

The Supreme Court reversed the judgment of the Appellate Court reversing the judgment of the trial court convicting Defendant of felony murder, home invasion, and robbery in the first degree, among other crimes. The Supreme Court held that the Appellate Court improperly concluded that the trial court (1) violated Defendant’s constitutional right to present a defense by conditioning its ruling that certain out-of-court statements were inadmissible under Crawford v. Washington, 541 U.S. 36, 68 (2004), on Defendant not presenting evidence regarding the statements; and (2) abused its discretion by admitting testimony from a police detective indicating that he had observed a purported bite mark on Defendant’s accomplice’s hand. Lastly, any claimed impropriety with respect to the admission testimony by a police detective who narrated the presentation of a bus surveillance video was harmless error. View "State v. Holley" on Justia Law

The Second Circuit sought the Connecticut Supreme Court's advice as to whether a Connecticut state marshal was entitled to the statutory fee of 15 percent on the amount of the execution for the levy of an execution, when the money is actually collected and paid over, or the debt is secured by the officer. In this case, the state court held that because the marshal levied the execution, he was entitled to a 15 percent fee under the terms of General Statutes 52-261 (a) (F). The state court also held that it did not matter that the writ was ignored and that the monies that were the subject of the writ were procured only after the judgment creditor, not the marshal, pursued further enforcement proceedings in the courts. View "Corsair Special Situations Fund, LP v. Engineered Framing Systems, Inc." on Justia Law

The Connecticut Supreme Court affirmed defendant's murder conviction and held that defendant expressly waived his claim that the trial court incorrectly failed to strike a witness's improper testimony. In this case, defendant had approved of the trial court's proposed remedy by expressing satisfaction with the trial court's plan to use an instruction, by declining to request action by the trial court, and by ultimately approving of the trial court's proposed instruction. The court also held that defendant's claim that the trial court improperly permitted the victim's mother to testify that she had heard information relating defendant to the victim's disappearance on the ground that it constituted inadmissible hearsay was unpreserved and unreviewable. View "State v. Miranda" on Justia Law