Justia Connecticut Supreme Court Opinion Summaries

Defendant served as Plaintiff’s defense counsel in a criminal jury trial in which Plaintiff was convicted of fourteen offenses. While awaiting sentencing, Plaintiff filed this action against Defendant, alleging legal malpractice and breach of fiduciary duty. After precluding Plaintiff from presenting expert testimony on the issue of causation due to her failure to disclose an expert witness by a date previously ordered, the trial court granted summary judgment in favor of Defendant. Plaintiff appealed, arguing that the trial court erred in concluding that expert testimony was necessary to prove her allegations. The Supreme Court affirmed, holding that expert testimony was required for Plaintiff to establish the element of causation in her legal malpractice case. View "Bozelko v. Papastavros" on Justia Law

James Doughty was injured during the course of his employment with Connecticut Reliable Welding, LLC (Reliable). Pacific Insurance Company, Ltd. (Pacific) had issued an insurance policy providing workers’ compensation coverage to Reliable and, therefore, paid Doughty workers’ compensation benefits. Pacific brought this action against Defendants - steel and construction companies - alleging negligence. Defendants moved to dismiss the complaint, arguing that that Pacific did not have standing to bring an action under either Conn. Gen. Stat. 31-293 or the common law doctrine of equitable subrogation. Pacific filed a motion to substitute Reliable as the party plaintiff. The trial court denied Pacific’s motion and granted Defendants’ motions to dismiss the complaint. The Supreme Court reversed, holding that a workers’ compensation insurer can maintain an equitable subrogation claim against third-party tortfeasors to recover benefits it has paid on behalf of an insured employer to an injured employee, and therefore, Pacific can properly assert an equitable subrogation claim. Remanded. View "Pacific Ins. Co., Ltd. v. Champion Steel, LLC" on Justia Law

Incident to the dissolution of his marriage to Plaintiff, Defendant was ordered to pay lump sum alimony in the amount of $7.5 million and attorney’s fees in the amount of $140,000. Defendant appealed, arguing that the lump sum alimony award constituted a functional property distribution in violation of the parties’ prenuptial agreement and that the award of attorney’s fees was an abuse of discretion. The Supreme Court affirmed in part and reversed in part, holding (1) the lump sum alimony award did not constitute a functional property distribution in contravention of the parties’ agreement; and (2) the trial court erred in awarding attorney’s fees to Plaintiff because Plaintiff received ample liquid funds as a result of the judgment. View "Hornung v. Hornung" on Justia Law

Defendant was charged with murder and other offenses. In 2010, the trial court found Defendant incompetent to stand trial. Thereafter, a judge found that Defendant had been restored to competency and granted his motion to represent himself. In 2015, the trial court again found Defendant incompetent to stand trial. After evidentiary hearings, the trial court granted the State’s motion for forcible medication of Defendant, finding that the State had established that forced medication would not violate Defendant’s federal due process rights under the test set forth by the United States Supreme Court in Sell v. United States. The Supreme Court affirmed, holding that the trial court correctly determined that forced medication was “substantially likely” to render Defendant competent to stand trial. View "State v. Wang" on Justia Law

Defendant entered a conditional plea of nolo contendere to possession of narcotics with intent to sell and failure to appear in the first degree. Defendant appealed, arguing that the trial court erred in denying Defendant’s motion to suppress narcotics evidence. The appellate court affirmed, concluding (1) the trial court correctly determined that Defendant was not seized until police officers performed a patdown search for weapons, and (2) the record was inadequate to review Defendant’s claim that he was unreasonably seized when two police cruisers descended upon him in a small parking lot and an officer verbally commanded him to stop. The Supreme Court reversed, holding (1) the appellate court erred in concluding that Defendant was not seized until the officers patted him down for weapons and that certain of Defendant's claims in that regard were unreviewable; and (2) the evidence Defendant sought to suppress was seized in violation of the federal and state constitutions. View "State v. Edmonds" on Justia Law

James Rock (the decedent) was employed by the University of Connecticut for more than thirty-five years before he died from a form of cancer that can be caused by occupational exposure to asbestos. The decedent never filed a notice of claim for workers’ compensation benefits. Plaintiff, the Estate of James Rock, filed a notice of claim for workers’ compensation benefits on behalf of the decedent. The Workers’ Compensation Commissioner dismissed Plaintiff’s claim for benefits for lack of standing. The Compensation Review Board upheld the dismissal but remanded the case to allow Plaintiff to advance a claim for burial expenses, lost wages the decedent sustained between his injury and his death, and medical expenses attributable to a compensable injury. The Supreme Court reversed in part, holding that an estate is not a legal entity capable of advancing a claim for any form of workers’ compensation benefits, and therefore, Plaintiff did not have standing to pursue any type of workers’ compensation benefits. View "Estate of Rock v. Univ. of Conn." on Justia Law

Plaintiff filed a complaint with the Freedom of Information Commission after the Connecticut Resources Recovery Authority (Defendant) failed to promptly produce certain requested communications. Defendant provided some documents to Plaintiff but withheld hundreds of others, asserting that the communications were covered by the attorney-client privilege. A hearing officer recommended that the Commission find that the documents were exempt from disclosure under the attorney-client privilege. Characterizing the communications as containing a mix of business and legal advice, the Commission voted to adopt the hearing officer’s decision. The superior court affirmed on appeal. The Supreme Court reversed, holding that the Commission failed to apply the proper standard for assessing the communications at issue. Remanded. View "Harrington v. Freedom of Info. Comm’n" on Justia Law

Before they were married, Wife and Husband entered a prenuptial agreement. Approximately ten years later, Wife brought a marital dissolution action against Husband. In accordance with an agreement to arbitrate in the prenuptial agreement, the trial court ordered the parties to proceed to arbitration on the matter of the sale of the parties’ residence. The arbitrator issued a partial award and then a final award. The trial court confirmed the partial award and confirmed in part, modified in part, and vacated in part the final arbitration award. Defendant appealed. The trial court subsequently entered judgment dissolving the marriage, allocating property, interpreting the prenuptial agreement, and deciding all pending motions. Defendant filed a second appeal. The Supreme Court affirmed, holding (1) the trial court properly applied Conn. Gen. Stat. 46b-66(c) to the agreement to arbitrate contained within the prenuptial agreement; (2) the trial court did not abuse its discretion by denying Defendant’s motion for leave to file an amended answer and cross complaint; and (3) the arbitrator did not exceed her authority by issuing orders in contravention of the express terms of the prenuptial agreement. View "LaFrance v. Lodmell" on Justia Law

Defendant was found guilty by a jury of burglary in the third degree and larceny in the third degree. The Appellate Court reversed defendant's convictions, concluding that it was plain error for the trial court not to instruct the jury, as mandated by General Statutes 54-84 (b), that it may draw no unfavorable inferences from defendant's failure to testify. The court granted the state’s petition for certification to appeal, limited to the issue of whether the Appellate Court properly reversed defendant’s conviction under the plain error doctrine. The court concluded that, even if a violation of section 54-84 (b) is subject to harmless error analysis, the state cannot establish that the violation in the present case was harmless beyond a reasonable doubt. Accordingly, the court affirmed the judgment. View "State v. Ruocco" on Justia Law

Plaintiff appeals, upon the court's grant of his petition for certification, from the judgment of the Appellate Court reversing the judgment of the trial court denying a motion of defendant to vacate a prior judgment by Judge Resha which "modified, by stipulation, a portion of the judgment of dissolution that ordered that the plaintiff’s pension benefits be divided equally between the parties." The court concluded that: (1) given a conflict in the case law on point and the Superior Court’s plenary jurisdiction over family relations matters, the Appellate Court improperly determined that it was ‘"entirely obvious" that Judge Resha lacked subject matter jurisdiction to modify the property distribution in the judgment of dissolution; and (2) considerations of finality of judgments, as set forth in section 12 of the Restatement (Second) of Judgments, do not support permitting defendant to mount a collateral attack on the modified judgment. Accordingly, the court reversed the judgment of the Appellate Court. View "Sousa v. Sousa" on Justia Law