Justia Connecticut Supreme Court Opinion Summaries

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After a jury trial, Defendant was convicted of, inter alia, murder with a firearm. The Appellate Court affirmed. Defendant appealed, arguing, in part, that the Appellate Court erred in determining that waiver of a claim of instructional error pursuant to State v. Kitchens precluded review of that claim under the plain error doctrine because the implied acquiescence of counsel cannot waive an error of such magnitude. The Supreme Court affirmed, holding (1) a Kitchens waiver does not necessarily foreclose plain error review of that same claim; but (2) the trial court’s decision not to instruct the jury on consciousness of guilt was not plain error. View "State v. McClain" on Justia Law

Posted in: Criminal Law
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After a jury trial, Defendant was convicted of, among other charges, carrying a pistol without a permit and unlawful possession of a weapon in a vehicle. Defendant was sentenced to a total effective term of twelve years of incarceration. The appellate court reversed in part and affirmed in part, holding that the evidence was insufficient to sustain Defendant’s conviction for carrying a pistol without a permit and unlawful possession of a weapon in a vehicle because the State failed to offer direct evidence to prove that Defendant lacked a temporary state pistol permit issued by a town in the first instance. The Supreme Court reversed in part, holding (1) the jury reasonably could have concluded that the evidence established that Defendant did not possess any pistol permit beyond a reasonable doubt; and (2) therefore, Defendant was properly found guilty of carrying a pistol without a permit and unlawful possession of a weapon in a vehicle. View "State v. Davis" on Justia Law

Posted in: Criminal Law
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After a jury trial, Defendant was convicted of murder. On appeal, Defendant’s principal claim was that the trial court violated his constitutional right to present a defense by refusing either to issue a summons to secure the attendance of a material witness in support of a theory of third-party culpability or to allow Defendant to introduce that witness’ statement to the police in lieu of her live testimony. The Supreme Court affirmed, holding (1) regarding Defendant’s argument regarding the issuance of a summons for the witness, defense counsel’s failure to locate the out-of-state witness with any reasonable degree of certainty precludes relief; and (2) none of Defendant’s remaining claims warrant reversal. View "State v. Bennett" on Justia Law

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When Employee received less compensation from Employer than that to which he believed he was entitled, Employee began to work for a competitor of Employer and to receive compensation for that work. Employer later terminated Employee’s employment and filed this action, alleging that Employee had breached the duty of loyalty to Employer by performing work on his own behalf during Employer’s workday and by accepting kickbacks from a subcontractor in connection with his work for Employer. The trial court held that Employee had violated his duty of loyalty to Employer. As part of its remedy, the trial court imposed a constructive trust on a bank account held jointly by Employee and his wife. The Supreme Court affirmed in part and reversed in part, holding (1) the trial court’s award of damages was supported by the evidence; (2) the trial court did not abuse its discretion in refusing to order additional monetary relief; and (3) the trial court’s imposition of a constructive trust on the joint bank account was not warranted on the evidence presented. View "Wall Systems, Inc. v. Pompa" on Justia Law

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Defendant was an attorney who represented clients in contingency fee matters that originated while he was a member of a two-person law firm with Plaintiff. After the dissolution of that firm, Defendant continued to represent those clients, and those fees were not paid until after the dissolution. Plaintiff brought this action claiming that Defendant’s failure to pay him those fees constituted, inter alia, breach of contract and unjust enrichment. The trial court concluded that Plaintiff was entitled to recover on his claim of unjust enrichment with respect to the contingency fee cases and found that Defendant owed Plaintiff $116,298.89. Defendant appealed, arguing that the award violated the fee splitting provisions of Rule 1.5(e) of the Rules of Professional Conduct because the clients had not consented to the fee sharing. The Supreme Court affirmed, holding that the trial court properly awarded Plaintiff a portion of the contingency fees that Defendant collected subsequent to the firm’s dissolution. View "Horner v. Bagnell" on Justia Law

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Defendant, the owner of real property, filed a subdivision map that purported to subdivide the property into three new parcels. Defendant, however, did not obtain permission from the city planning and zoning authorities before filing the revised subdivision map. Defendant subsequently obtained a mortgage loan from a predecessor-in-interest to the substitute plaintiff. The loan was secured by a mortgage on two of the tracts. Defendant later defaulted on the mortgage loan, and plaintiff’s predecessor-in-interest commenced this action to foreclose on the mortgage. Defendant objected to the foreclosure, arguing that a judgment of foreclosure would have the effect of validating an illegal subdivision of property. The trial court rendered judgment in favor of Plaintiff and ordered a strict foreclosure of the two tracts. The Supreme Court affirmed, holding that a trial court may render a judgment of foreclosure on mortgaged property that consists of parcels of land within a subdivision that has not been approved by municipal zoning authorities. View "ARS Investors II 2012-1 HVB, LLC v. Crystal, LLC" on Justia Law

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Plaintiff entered into a purchase agreement providing that Plaintiff was to provide various telecommunications equipment, software, and services to Defendant for a switch room located in Los Angeles. Defendant later terminated the purchase agreement. Plaintiff filed a complaint claiming breach of contract for Defendant’s failure to pay the amounts owed and account stated. Defendant counterclaimed for, inter alia, breach of contract for Plaintiff’s failure to provide services under the purchase agreement. The trial court entered judgment for Defendant on the complaint and the breach of contract count of the counterclaim. The court later articulated that Plaintiff had breached the purchase agreement. The Supreme Court affirmed, holding that the trial court (1) did not err in concluding that Plaintiff breached the purchase agreement; (2) did not err in finding that Plaintiff failed to prove its breach of contract claim; and (3) properly awarded damages, cost and attorney’s fees in light of a limitation of liability clause in the purchase agreement. View "CCT Communications, Inc. v. Zone Telecom, Inc." on Justia Law

Posted in: Contracts
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A police union and the City of Norwalk were parties to a collective bargaining agreement (CBA) governing the terms and conditions of employment for certain city police officers. The CBA provided that disputes over its interpretation will be resolved through arbitration. The Board of Police Commissioners determined that Stephen Couture, a police sergeant employed by the Norwalk Police Department, had violated departmental rules and that his employment should be terminated. Couture ultimately initiated an arbitration proceeding with the State Board of Mediation and Arbitration, and a majority of the arbitration board found that Couture had been terminated for just cause. The trial court vacated the arbitration award on the ground that the City had disciplined Couture twice for the same misconduct in manifest disregard of the law. The Supreme Court reversed, holding that the arbitration board’s decision was not in manifest disregard of the law, and therefore, the trial court improperly vacated the award of the arbitration board. View "Norwalk Police Union, Local 1727 v. City of Norwalk" on Justia Law

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After a jury trial in 1997, Petitioner was found guilty of murder and criminal possession of a firearm. the trial court sentenced Petitioner to an aggregate term of sixty years’ imprisonment. Petitioner later filed an amended petition for a writ of habeas corpus containing four counts. The habeas court denied the petition. The appellate court affirmed, concluding that Petitioner failed to meet his burden of demonstrating that the deficient performance of defense counsel in responding to the trial court’s treatment of a jury note had prejudiced Petitioner. The Supreme Court affirmed, holding that Petitioner received constitutionally adequate representation at trial. View "Taylor v. Commissioner of Correction" on Justia Law

Posted in: Criminal Law
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After a jury trial, Defendant was convicted of three counts of interfering with an officer. The Appellate Court reversed, concluding that the trial court abused its discretion in allowing the state to allow a midtrial amendment charging additional offenses. The Supreme Court affirmed, holding (1) the trial court abused its discretion in allowing the state to amend the information without good cause to charge additional offenses, but that impropriety does not require reversal in the absence of prejudice; and (2) the improper amendment was not harmless beyond a reasonable doubt under the circumstances of this case. View "State v. Ayala" on Justia Law

Posted in: Criminal Law