Justia Connecticut Supreme Court Opinion Summaries

Plaintiff, the owner of a parcel of land in the Town of Colchester, challenged the Town’s assessment of the property for the tax year 2011. The Colchester Board of Assessment Appeals upheld the Town’s original valuation. Plaintiff appealed, arguing that the Town had used an improper method for valuing the property. The trial court upheld the Town’s original assessment, determining that Plaintiff had not established that it was aggrieved by the Town’s valuation because it found that Plaintiff’s expert was not credible. Plaintiff appealed, arguing that the trial court applied the incorrect legal standard of valuation to the subject property. The Supreme Court affirmed, holding that the trial court’s determination that Plaintiff failed to establish aggrievement was not clearly erroneous, and the trial court properly rejected Plaintiff’s appeal. View "Nutmeg Housing Development Corp. v. Colchester" on Justia Law

Defendant was charged by criminal information with sexual assault in the first degree and risk of injury to a child. Based on the seriousness of the offenses and the allegation that Defendant’s conduct occurred when he was fourteen years old, the case was automatically transferred from the juvenile docket to the regular criminal docket. After a jury trial, Defendant was convicted of two counts of sexual assault int he first degree and one count of risk of injury to a child. The Appellate Court vacated the convictions, concluding that the trial court erred by denying Defendant’s post trial motion to dismiss the information because the State had failed to prove beyond a reasonable doubt that the conduct underlying the convictions had occurred after Defendant’s fourteenth birthday. The Supreme Court affirmed, holding that the State did not establish, under any burden of proof, that Defendant was at least fourteen years old at the time he committed the offenses for which he was convicted. View "State v. Samuel M." on Justia Law

Defendant was convicted of murder. Defendant committed the crime when he was seventeen years old. In 1992, Defendant was sentenced to fifty years’ imprisonment without parole. In 2013, Defendant filed a motion to correct his allegedly illegal sentence, arguing that he was entitled to resentencing on the basis of recent changes to juvenile sentencing law. The trial court dismissed the motion for lack of jurisdiction. The Supreme Court affirmed, holding that court precedent does not require a trial court to consider any particular mitigating factors associated with a juvenile’s age before imposing a sentence that includes an opportunity for parole, and therefore, Defendant has not raised a colorable claim of invalidity that would require resentencing. View "State v. Boyd" on Justia Law

In 1996, Defendant was sentenced to sixty-five years imprisonment without parole for crimes that he committed when he was a juvenile. Under recent changes to juvenile sentencing law, a juvenile who has been convicted of murder to life in prison without parole may not be sentenced to life in prison unless the court considers mitigating factors associated with the juvenile’s age at the time of the crimes. Defendant was sentenced before these changes occurred. In 2014, Defendant filed a motion to correct his allegedly illegal sentence, arguing that the judge who sentenced him failed to consider youth-related mitigating factors. The trial court dismissed Defendant’s motion to correct. The Supreme Court affirmed, holding that the sentencing court lacked jurisdiction to correct the sentence, as Defendant did not claim that the sentence was illegal or was imposed in an illegal manner. View "State v. Delgado" on Justia Law

In 2006, Plaintiff’s decedent filed notices of claim with the Workers’ Compensation Commission. The Commission assigned the decedent’s claims to its asbestos docket for adjudication. After the decedent died, Plaintiff, his widow, filed a claim for dependent benefits that was joined with the original claims. The Connecticut Insurance Guaranty Association became a defendant in the proceedings. The Association was originally dismissed from the case for lack of exposure. The Commissioner later reinstated the Association as a party to the proceedings. The Workers’ Compensation Review Board affirmed. The Supreme Court affirmed the Board’s decision, holding that the Commissioner properly reinstated the Association as a party to the proceedings because the Commissioner’s broad case management authority permitted him to render a dismissal that was provisional, rather than final, in nature. View "Graham v. Olson Wood Associates, Inc." on Justia Law

The Commissioner of Children and Families filed a petition for termination of Mother’s parental rights to her minor child. The trial court terminated Mother’s parental rights. The Supreme Court affirmed, holding (1) Mother failed to demonstrate that her right to procedural due process was violated by the trial court’s consideration of the prior voluntarily termination of Mother’s parental rights with respect to another child when Mother was a minor; and (2) the trial court did not err in finding that the Department of Children and Families had made reasonable efforts toward reunification, that Mother was unable or unwilling to benefit from those reasonable efforts, and that Mother had failed to rehabilitate. View "In re Jayce O." on Justia Law

In 1989, Connecticut National Mortgage Company brought this action seeking to foreclose a mortgage on a parcel of real property owned by Defendant. The trial court rendered a judgment of foreclosure in 1994. That judgment has been opened and modified several times over the years. In 2012, Wells Fargo Bank, N.A. was substituted as the plaintiff. On June 8 2015, the trial court entered a new judgment of strict foreclosure extending defendant’s law day to August 4, 2015. On June 18, 2015, the trial court denied Defendanat’s motion to vacate the new judgment. On June 26, 2015, Defendant filed an appeal. On January 13, 2016, the Appellate Court dismissed the appeal as moot. The Supreme Court reversed, holding that the June 8, 2015 judgment triggered an automatic stay and that the appellate stay prevented title from vesting in the plaintiff by operation of law when Defendant failed to exercise her right of redemption on August 4, 2015. Therefore, the case should not have been dismissed as moot. View "Connecticut National Mortgage Co. v. Knudsen" on Justia Law

Plaintiff filed a complaint against the Commissioner of Environmental Protection (Commissioner) and Dominion Nuclear Connecticut, Inc. (Dominion) alleging that the operation of the Millstone Nuclear Power Station owned and operated by Dominion was causing unreasonable pollution of the state’s waters in violation of the Connecticut Environmental Protection Act of 1971. The trial court dismissed the complaint on the ground that Plaintiff lacked standing. The Supreme Court reversed, concluding that Plaintiff had standing to bring her action under Conn. Gen. Stat. 22a-16. The Court ordered the trial court to conduct a hearing to determine whether the pending administrative permit renewal proceeding for the nuclear power station’s operation was inadequate to protect the rights recognized by the Act. The administrative proceeding then terminated when the Commissioner issued a renewal permit for Millstone. The trial court granted Defendants’ motions to dismiss, concluding that Plaintiff’s action was moot. The Supreme Court reversed, holding that Plaintiff’s claims were not moot because a determination that the renewal proceeding was inadequate to protect the rights recognized under the Act could result in the invalidation of the permit under which Millstone is currently operating. View "Burton v. Commissioner of Environmental Protection" on Justia Law

After a second jury trial, Defendant was found guilty of one count of sexual assault in the fourth degree. The Appellate Court affirmed, concluding that the trial court properly denied Defendant’s request to strike a juror for cause even when Defendant had shown that the juror was a police officer with possible ties to the agency investigating Defendant’s case. Defendant appealed, claiming that the challenged juror’s bias should have been conclusively presumed. The Supreme Court affirmed, holding that there was an insufficient factual basis for the trial court to find the type of close relationship between the challenged juror and a party or witness that would require disqualification as a matter of law, and therefore, the trial court did not err in denying Defendant’s challenge with respect to that juror. View "State v. Benedict" on Justia Law

The trial court terminated the parental rights of Father to his child. The trial court filed the memorandum of decision terminating Father’s parental rights approximately two weeks after publication of the Supreme Court’s decision in In re Yasiel R. The Appellate Court reversed, concluding that the trial court’s failure to canvass Father prior to the commencement of the trial in accordance with the rule promulgated pursuant to the exercise of the Supreme Court’s supervisory authority in In re Yasiel R. applies retroactively to the present case. The Supreme Court reversed, holding that applying the canvass rule announced in In re Yasiel R. to the instant case would exceed the scope of the exercise of the Court’s supervisory authority in that case. View "In re Daniel N." on Justia Law