Justia Connecticut Supreme Court Opinion Summaries

Defendants were the beneficiaries of a trust settled by the decedent. Plaintiffs brought this action seeking, inter alia, a declaratory judgment determining the rights and ownership interests of Defendants in a certain parcel of real property. The trial court awarded summary judgment in favor of Defendants, determining that the decedent’s failure to record a separate document limiting his powers “as trustee” in accordance with Conn. Gen. Stat. 47-20, when the decedent quitclaimed the real property to himself as trustee, did not have the effect of nullifying the transfer of the property to the trust corpus, thereby disallowing the decedent, as an individual, to subsequently devise that property to Plaintiffs through his will. The Supreme Court affirmed, holding that section 47-20 did not apply in this case. Therefore, section 47-20 did not nullify the decedent’s quitclaim deed to himself as trustee, the property was a trust asset, and the specific devise in the decedent’s will was adeemed. View "Lackman v. McAnulty" on Justia Law

Defendant Gary Proctor set up an account of electric services for a new business. After Defendant contacted Plaintiff, Connecticut Light and Power Company, Plaintiff provided electric service to the business under an account in Defendant’s name until it disconnected service for non-payment. Plaintiff then brought an action against Defendant for breach of an implied contract and unjust enrichment seeking $14,620 in outstanding bills. The trial court rendered judgment for Plaintiff on the breach of an implied contract count, finding that Defendant manifested assent to enter into an implied in fact contract with Plaintiff under which Defendant would be responsible for payment for the provision of electric services to the company. The Appellate Court affirmed. The Supreme Court affirmed, holding that there was sufficient evidence to support the trial court’s finding that Defendant entered into an implied in fact contract with Plaintiff. View "Connecticut Light & Power Co. v. Proctor" on Justia Law

After he was terminated, Employee sued Employer, alleging, inter alia, disability discrimination. After a trial, the jury trial returned a verdict in favor of Employee and awarded him, inter alia, $500,000 in statutory punitive damages. Employer moved to set aside the award of punitive damages. The trial court granted the motion, determining that Conn. Gen. Stat. 46a-104 does not provide for an award of statutory punitive damages as a remedy for discriminatory practices under the Connecticut Fair Employment Practices Act. The Appellate Court affirmed. The Supreme Court affirmed, holding that section 46a-104 does not authorize punitive damages in employment discrimination cases. View "Tomick v. United Parcel Service, Inc." on Justia Law

At issue in this case was whether, under Connecticut law, after a judgment debtor’s wages have been garnished, the remaining wages are exempt from execution, and whether the transfer of those wages to a third party constitutes a fraudulent transfer. Pursuant to two state court judgments, The Cadle Company was Terry Fletcher’s judgment creditor, Fletcher owing the company more than $3 million. Since at least 2005, Terry has transferred more than $300,000 of his residual wages to the bank account of his wife, Marguerite Fletcher. The Cadle Company sued the Fletchers in federal district court, alleging, inter alia, that the transfer violated the Connecticut Uniform Fraudulent Transfer Act (CUFTA). The district court granted the Fletchers’ motion for partial summary judgment, granted The Cadle Company’s motion for partial summary judgment, and ultimately rendered judgment for The Cadle Company in the amount of $401,426 on its CUFTA claim. The Fletchers appealed to the Second Circuit Court of Appeals. The Second Circuit subsequently certified a question to the Supreme Court, which the Court accepted. The Supreme Court answered that Terry’s residual wages would not have been exempt from execution if he had retained possession of them, and therefore, they were subject to execution after Terry transferred them to his wife’s account. View "Cadle Co. v. Fletcher" on Justia Law

After a jury trial, Defendant was convicted of sexual assault in the first degree and other offenses. The trial court rendered judgment in accordance with the jury’s verdict. The Appellate Court reversed the judgment and remanded the case for a new trial, holding that the State deprived Defendant of his constitutional right to remain silent when the prosecutor noted twice during closing arguments that Defendant had not testified in his own defense. The Supreme Court affirmed, holding (1) the prosecutor’s two statements clearly violated Defendant’s Fifth Amendment right to remain silent; and (2) the State failed to meet its burden of proof that the prosecutor’s comments were harmless beyond a reasonable doubt. View "State v. A. M." on Justia Law

Petitioner was charged with several criminal offenses. Petitioner pleaded not guilty by reason of mental disease or defect. After a nonadversarial proceeding, the court rendered a judgment acquitting Petitioner of all offenses on the basis of mental disease or defect and committed Petitioner to the custody of the Commissioner of Mental Health and Addiction Services (Respondent) for a period not to exceed twenty-five years. Respondent later transferred custody of Petitioner to the jurisdiction of the Psychiatric Security Review Board. Petitioner remained committed to the custody of the Board for more than twenty-five years. Petitioner then filed a petition for habeas corpus challenging his extended confinement. The habeas court denied Petitioner’s petition. The Supreme Court affirmed, holding (1) the habeas court properly denied Petitioner relief on his claim regarding the knowing and voluntary nature of his plea; and (2) the habeas court correctly determined that Petitioner did not receive ineffective assistance of counsel. View "Dyous v. Commissioner of Mental Health & Addiction Services" on Justia Law

Defendant lived in a unit of a multiunit condominium complex. When the police department received an anonymous tip that Defendant was boasting about growing marijuana in his unit, the police entered the building with a drug dog and conducted a directed search in which the dog sniffed at the common floor hallways and at the bottom of the door to Defendant’s unit. The officers later returned with a search warrant, and Defendant was subsequently arrested and charged with several drug offenses and illegal possession of an assault weapon. Defendant filed a motion to suppress, arguing that the canine sniff of the threshold of his unit for the purpose of investigating the unit’s contents constituted a search within the meaning of article first, section seven of the Connecticut Constitution and the Fourth Amendment of the United States Constitution. The trial court granted the motion to suppress, concluding that the canine sniff constituted a search within the meaning of the Fourth Amendment and, therefore, required a warrant predicated on probable cause. The Supreme Court affirmed, holding that a canine sniff directed toward a home is a search under article first, section seven of the Connecticut Constitution and, as such, requires a warrant issued upon a court’s finding of probable cause. View "State v. Kono" on Justia Law

Plaintiff brought a personal injury action against Defendants. After a jury trial, Plaintiff was awarded $84,283 in economic damages and $40,000 in noneconomic damages. Defendants moved for a collateral source reduction to the award pursuant to Conn. Gen. Stat. 52-225a, arguing that the economic damages award should be reduced to account for the fact that Plaintiff had paid only $1941 toward his medical expenses and his health insurance coverage had covered the remainder. Plaintiff objected to reduction, arguing that section 52-225a precludes a collateral source reduction when a right of subrogation exists, as it did in the present case. The trial court ordered a collateral source reduction of $24,299. The Supreme Court reversed, holding that the trial court erred in ordering a collateral source reduction to the award of economic damages to Plaintiff when there was a right of subrogation, in violation of section 52-225a. View "Marciano v. Jiminez" on Justia Law

Plaintiffs were four bus companies operating buses over routes in and around the cities of New Britian and Hartford. Each plaintiff had authority to operate a bus service over a specific route pursuant to a certificate of public convenience and necessity. When a new busway was constructed by the state, the state sought to hire new companies to operate buses over the routes Plaintiffs currently operate. In a separate action, Plaintiffs sought to enjoin the Commissioner of Transportation from transferring the routes at issue to new operators. While that case was pending, the Commissioner condemned the certificates pursuant to the State’s power of eminent domain. Plaintiff filed the actions that were the subject of this appeal, claiming that the Commissioner lacked the statutory authority to condemn their certificates. The trial court consolidated the actions and granted the Commissioner’s motion for summary judgment, concluding that Conn. Gen. Stat. 13b-36(a) gave the Commissioner authority to condemn the certificates. The Supreme Court reversed, holding that the legislature did not intend for the term “facilities” in the statute to refer to intangible operating rights reflected in the certificates at issue. View "Dattco, Inc. v. Commissioner of Transportation" on Justia Law

Plaintiff was employed as a police officer by Defendant when he was injured. The Workers’ Compensation Commissioner dismissed Plaintiff’s claim for Workers’ Compensation benefits, concluding that Plaintiff had not departed his “place of abode” for duty as a police officer at the time he sustained his injury, and therefore, the incident was not compensable. The Workers’ Compensation Board affirmed. The Supreme Court reversed, holding that Plaintiff was acting “in the course of his employment” at the time he was injured, and therefore, the Board erred in affirming the Commissioner’s decision to dismiss Plaintiff’s claim. View "Balloli v. New Haven Police Department" on Justia Law