Justia Connecticut Supreme Court Opinion Summaries

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

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