Justia Connecticut Supreme Court Opinion Summaries

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

In 2006, Angel Agron was arrested and charged with several offenses. The trial court set bail on these charges in an amount totaling $20,000. 3-D Bail Bonds (Plaintiff) executed a bail on that amount, and Agron was released from custody. When Agron did not appear for a scheduled court date, the trial court ordered the total amount of the bond forfeited. Plaintiff filed a motion to release Plaintiff from its obligation on the bond pursuant to Conn. Gen. Stat. 54-65c, asserting that Agron was “detained” in Puerto Rico by bail enforcement agents. The trial court denied the motion. Plaintiff thereafter filed a writ of error. The Supreme Court dismissed the writ of error, holding that the trial court did not err in concluding that Agron was not “detained” for purposes of section 54-65c when he was personally confronted by recovery bail enforcement agents in Puerto Rico. View "State v. Agron" on Justia Law

After a jury trial, Defendant was convicted of murder, using a firearm in the commission of a felony, carrying a pistol without a permit, and criminal possession of a pistol or revolver. The trial court sentenced Defendant to seventy years of incarceration. Defendant appealed, arguing that the trial court abused its discretion in admitting a Facebook profile page and photographs. Specifically, Defendant argued that the evidence was not properly authenticated. The Supreme Court affirmed, holding that, assuming, without deciding, that the trial court improperly admitted the evidence, any error relating to the admission of the evidence would have been harmless. View "State v. Bouknight" on Justia Law

In 1996, Plaintiff was hired by Defendant, the New Haven Police Department, as a police officer. In 2011, Plaintiff suffered a myocardial infarction. Plaintiff later filed a claim for benefits under Conn. Gen. Stat. 7-433c(a) for hypertension and heart disease. The Workers’ Compensation Commissioner dismissed Plaintiff’s claim for benefits related to his hypertension as untimely but granted his claim for benefits related to his heart disease and myocardial infarction. The Workers’ Compensation Review Board affirmed. Defendant appealed, arguing that the Board improperly affirmed the Commissioner’s decision that Plaintiff’s hypertension and heart disease were separate diseases, each with its own limitation period for filing a claim for benefits. The Supreme Court affirmed, holding (1) the medical evidence supported the Board’s conclusion that Plaintiff’s hypertension and heart disease were separate medical conditions; and (2) the Board properly affirmed the Commissioner’s decision granting Plaintiff benefits pursuant to section 7-433c related to heart disease. View "Holston v. New Haven Police Department" on Justia Law

Plaintiff commenced this action against Defendants, the superintendent of schools for the Town and the principal of Bacon Academy, among others, after he was struck by a vehicle at the school’s driveway. Plaintiff alleged that Defendants negligently supervised school staff and students during school hours and sought indemnification from the Town for those defendants’ negligence. The Town, superintendent, principal, assistant principals, and members of the Town’s Board of Education moved for summary judgment claiming that governmental immunity shielded them from liability. The trial court granted summary judgment with respect to those defendants, concluding that their duty to supervise school staff and students was discretionary. The Supreme Court affirmed in part and reversed in part, holding (1) the trial court erred in granting summary judgment as to the assistant principals with respect to Plaintiff’s claim that they breached their ministerial duty to assign school staff to supervise students during school hours; and (2) the trial court properly granted summary judgment in all other respects. View "Strycharz v. Cady" on Justia Law

After party caucuses hosted by the two factions comprising the state’s Independent Party, two different nominees for the United States Senate were certified to the secretary of state. The Independent Party of CT-State Central nominated Daniel Carter, and the Independent Party of Connecticut nominated John Price. The secretary of state notified the factions that neither name would be placed on the ballot under the Independent Party line unless one nominee withdrew. Price, the Independent Party of Connecticut, and a member of that party (collectively, Plaintiffs) filed this action alleging various violations of party rules and election statutes during the caucus of the Independent Party of CT-State Central and seeking relief under Conn. Gen. Stat. 9-323. Plaintiffs sought a permanent injunction compelling Carter to withdraw his nomination and compelling the secretary of state to place Price’s name on the November, 2016 ballot. The Supreme Court granted Defendants’ motion to dismiss, holding (1) officials administering minor party caucuses are not “election officials” for purposes of section 9-323, and therefore, Plaintiffs were not aggrieved under the statute by the actions of those officials; and (2) even if Plaintiffs’ claims fell within the purview of section 9-323, the doctrine of laches would operate as an adequate ground to dismiss Plaintiffs’ action. View "Price v. Independent Party of CT--State Central" on Justia Law

After a jury trial, Defendant was convicted of conspiracy to distribute one kilogram or more of a cannabis-type substance and possession of one kilogram or more of a cannabis-type substance with intent to sell as an accessory. Defendant appealed, claiming that the trial court had incorrectly instructed the jury on the state of mind required to find him guilty of the offenses. Applying the waiver rule in State v. Kitchens, the Appellate Court concluded that Defendant failed to preserve his claim. Defendant appealed, requesting that the waiver rule established in Kitchens be overturned and that his claim be reviewed under State v. Golding. The Supreme Court affirmed, holding (1) the rule in Kitchens should not be overturned; and (2) Defendant’s request to review his claim under the plain error doctrine is declined because such review is beyond the scope of the certified question. View "State v. Herring" on Justia Law

After a jury trial, Defendant was convicted of two counts of murder and other crimes. Defendant appealed, claiming, inter alia, that the jury instructions on the issue of the accuracy of an identification were prejudicially erroneous and deprived him of a fair trial. Applying the waiver rule in State v. Kitchens, the Appellate Court ultimately concluded that the claim had been waived. The Supreme Court affirmed, holding (1) the Appellate Court did not err in concluding that Defendant waived his unpreserved jury instruction under the rule established in Kitchens; and (2) the rule in Kitchens should not be overturned. View "State v. Bellamy" on Justia Law