Justia Connecticut Supreme Court Opinion Summaries

After hiring Plaintiff, Defendant-employer amended its sales commission plan. At dispute in this case was a revised commission provision, which provided that Plaintiff’s commissions would not be paid unless Defendant had invoiced commissionable amount to the client prior to Plaintiff’s termination. After Plaintiff was terminated, he filed a wage statute claim alleging that the commission provision was contrary to public policy and a violation of Conn. Gen. Stat. 31-72. Plaintiff’s remaining two claims were stricken upon Defendant’s motion. After a trial, the court granted judgment in favor of Plaintiff, holding that the commission provision at issue was contrary to public policy. Both parties appealed. The Supreme Court affirmed in part and reversed in part, holding that the trial court (1) improperly determined that the commission provision violated public policy and constituted a violation of section 31-72; (2) erred in striking Plaintiff’s claim alleging breach of the implied covenant of good faith and fair dealing; and (3) did not err in striking Plaintiff’s claim alleging wrongful discharge. Remanded. View "Geysen v. Securitas Security Servs. USA, Inc." on Justia Law

Nicholas Giannoni was riding his bicycle on the sidewalk along a state highway. The highway ended at a private driveway and lawn and led directly to a stream culvert. When the sidewalk ended, Nicholas inadvertently rode his bicycle across the driveway, over a patch of grass, and into the culvert, injuring himself. Plaintiffs brought this highway defect action on behalf of Nicholas under Conn. Gen. Stat. 31a-144 against the Commissioner of Transportation. The Commissioner moved to dismiss the complaint on the ground of sovereign immunity. The trial court denied the motion. The Supreme Court affirmed, holding that Plaintiffs alleged a cognizable highway defect claim under section 31a-144. View "Giannoni v. Comm’r of Transp." on Justia Law

Plaintiff’s husband was employed by Defendant. Plaintiff discovered her husband’s dead body beneath a vehicle when bringing lunch to him at work. Plaintiff received survivors’ benefits under Defendant’s workers’ compensation insurance policy. Thereafter, Plaintiff sued Defendant for negligent infliction of bystander emotional distress. The trial court granted Defendant’s motion for summary judgment based on the language of the exclusivity provision of the Workers’ Compensation Act and the derivative nature of claims for bystander emotional distress. The Supreme Court affirmed, holding that because the Act applies to the parties in this case and there is a causal link between Plaintiff’s claim for bystander emotional distress and a compensable injury, Plaintiff’s claim was barred. View "Velecela v. All Habitat Servs., LLC" on Justia Law

Defendant served as the general contractor for the construction of a gas fired power plant and implemented a contractor controlled insurance program (CCIP) to centralize the purchasing of workers’ compensation insurance for the project. Plaintiffs, employees of Defendant’s subcontractors, were injured at an explosion that occurred at the power plant construction site. Plaintiffs received workers’ compensation benefits under the CCIP. Plaintiffs subsequently brought this action against Defendant under Conn. Gen. Stat. 31-293(a), asserting negligence and strict liability claims. The trial court granted summary judgment in favor of Defendant, concluding that Defendant “paid” workers’ compensation benefits to Plaintiffs, thus entitling it to “principal employer” immunity. The Supreme Court affirmed, holding (1) the trial court erred in interpreting the term “paid compensation benefits” in section 31-291; but (2) even under the proper construction of section 31-291, no genuine issue of material fact exists as to whether Defendant paid compensation benefits to Plaintiffs. View "Gonzalez v. O. & G. Indus., Inc." on Justia Law

After a jury trial, Defendant was convicted of murder. Defendant appealed, arguing that the trial court violated his right to present a defense by limiting his cross-examination of investigating police officers as to whether the murder investigation conformed to general police practices and/or standard police investigative procedures. The Appellate Court agreed with Defendant and reversed and remanded the case for a new trial. The Supreme Court reversed, holding that there was an absence of a sufficient offer of proof to such a line of inquiry, and therefore, the trial court did not improperly preclude Defendant’s inadequate investigation defense strategy. View "State v. Wright" on Justia Law

In 1992, Defendant was convicted of murder. In 2010, Defendant filed a third motion to correct an illegal sentence. The trial court denied the motion on the merits. Defendant appealed, arguing that the trial court violated his right to counsel by denying his request for the assistance of counsel without adhering to the procedure set forth in Anders v. California. The Appellate Court reversed the trial court’s denial of Defendant’s request for the appointment of counsel, holding that Anders applied to Defendant’s claim and that the requirements of Anders were not satisfied in this case. The Supreme Court affirmed, holding (1) the Anders procedure is not required to safeguard the statutory right to counsel in the context of a motion to correct an illegal sentence; but (2) the trial court erred by failing to appoint counsel to assist Defendant in determining whether a sound basis existed for him to file his motion, and the error was not harmless. View "State v. Francis" on Justia Law

The Commissioner of Children and Families (Petitioner) filed petitions to terminate the parental rights of Mother and Father (together, Respondents) to their two minor children. The trial court granted the petitions. Respondents appealed, claiming that the trial court erred in finding that Petitioner made reasonable efforts to reunify Respondents with their children and that Respondents were unable to unwilling to benefit from reunification efforts. The Supreme Court affirmed, holding (1) a finding that no reunification efforts were required is an independent basis upon which the trial court could have terminated the parental rights of Respondents; and (2) Respondents’ appeals would be moot because they did not timely appeal from that finding, but such a result would violate Respondents’ due process rights under the circumstances of this case. Remanded for a new trial. View "In re Egypt E." on Justia Law

Plaintiff was a registered sex offender when he was admitted to the state rental assistance program. Thereafter, the legislature promulgated section 17b-812-13(9) of the Regulations of Connecticut States Agencies, which makes sex offender registration a ground for termination or denial of rental program assistance. The Commissioner of Housing (Commissioner) subsequently terminated Plaintiff’s rental program benefits. Plaintiff took an administrative appeal of the Commissioner’s decision to the trial court, which concluded that the Commissioner’s application of section 17b-812-13(9) was not retroactive and therefore did not exceed the authority granted to the Commissioner by the legislature. The Supreme Court reversed, holding (1) the Commissioner applied section 17b-812-13(9) of the regulations retroactively in this case by imposing a new obligation on Plaintiff’s sex offender status that terminated his rental program assistance; and (2) such retroactive application of the regulation was not statutorily authorized, and therefore, the trial court erred in dismissing Plaintiff’s administrative appeal. View "Shannon v. Comm’r of Housing" on Justia Law

After a jury trial, Petitioner was convicted of capital felony and other crimes. Petitioner was sentenced to death. Petitioner later filed a petition for a writ of habeas corpus, raising several challenges to his death sentence. The habeas court denied the petition. After Petitioner filed his appeal, the Supreme Court granted Petitioner permission to file a supplemental brief on the question of whether the legislature’s enactment of P.A. 12-5 rendered the death penalty, as applied to him and other similarly situated defendants, unconstitutional. While the appeal was pending, the Supreme Court decided State v. Santiago, which held that the imposition of the death penalty on defendants sentenced to death for capital crimes committed before the effective date of the legislation was unconstitutional under the state constitution. The Supreme Court reversed the denial of Petitioner’s habeas petition, holding that the death penalty was unconstitutional as applied to Petitioner. View "Webb v. Commissioner of Correction" on Justia Law

After a jury trial, Defendant was convicted of sexual assault in the first degree and sexual assault in the third degree. The Supreme Court affirmed, holding (1) the trial court properly denied Defendant’s motion to suppress statements he made to the police; (2) the trial court properly admitted evidence of uncharged sexual misconduct pursuant to State v. DeJesus; and (3) the trial court’s application of the Supreme Court’s decision in DeJesus and the relevant revision of section 4-5(b) of the Connecticut Code of Evidence did not violate Defendant’s equal protection rights under the federal and state constitutions. View "State v. Arias" on Justia Law