Justia Connecticut Supreme Court Opinion Summaries

As part of a marriage dissolution settlement agreement, Joyce Styslinger assigned her membership interest in Brewster Park, LLC to William Styslinger (Plaintiff). Plaintiff had the right to receive distributions resulting from Joyce’s membership interest in the LLC, while Joyce remained a member of Brewster Park until Plaintiff was admitted to membership by Michael Weinshel, the other member of the LLC. At the time he filed this action, Plaintiff had requested membership status, but Weinshel had not granted it, and Brewster Park had not made any distributions to Plaintiff despite Plaintiff’s demand. Plaintiff sued Brewster Park and Weinshel claiming breach of fiduciary duty and seeking an order dissolving Brewster Park and the appointment of a receiver to wind up its affairs and distribute its assets. The trial court dismissed the complaint on the ground that Plaintiff lacked standing to seek a dissolution or a winding up of the LLC’s assets. Plaintiff appealed, arguing that the Connecticut Limited Liability Company Act granted him standing in this case. The Supreme Court affirmed, holding that the assignee of a membership interest in a Connecticut LLC does not have standing to seek a winding up of the affairs of the LLC in the absence of the LLC’s dissolution. View "Styslinger v. Brewster, Park, LLC" on Justia Law

Defendant was charged with a number of crimes in connection with the abduction of his former wife. The trial judge found Defendant competent to represent himself at trial and permitted Defendant to represent himself. A jury subsequently convicted Defendant of all but one of the charges against him. The Supreme Court remanded the case to the trial court with direction to reconsider Defendant’s competency to represent himself in light of a new standard that the Court adopted in Defendant’s direct appeal. On remand, the trial judge concluded that Defendant had been competent to represent himself at the time of his trial. The Appellate Court reversed, concluding that the trial court’s remand hearing was procedurally flawed. The Supreme Court reversed, holding that the Appellate Court’s decision to resolve the appeal sua sponte on the basis that the remand hearing was procedurally flawed violated Blumberg Associates Worldwide, Inc. v. Brown & Brown of Connecticut, Inc. Remanded to the Appellate Court with direction to consider the issue raised in Defendant’s appeal. View "State v. Connor" on Justia Law

After a jury trial, Defendant was convicted of two counts of assault in the second degree. Defendant appealed, arguing that the trial court’s denial of his motion to suppress his statements to the police made during his booking violated his Fifth Amendment rights and that he was subjected to custodial interrogation without Miranda warnings at the crime scene. The Appellate Court affirmed, holding that the public safety exception to Miranda, as articulated in New York v. Quarles, applied. The Supreme Court affirmed, holding that, based on the circumstances of this case, the public safety exception applied. View "State v. Smith" on Justia Law

Plaintiff, the beneficiary of a testamentary trust, entered a long-term care facility in 2012, at which time she applied for financial and medical assistance under Medicaid. The Department of Social Services denied the application for Medical benefits, finding that Plaintiff’s assets, including the trust, exceeded the relevant asset limits. A hearing officer upheld the department’s denial. Plaintiff appealed, arguing that the trust was not an asset available to her as defined by relevant Medicaid regulations. The trial court dismissed Plaintiff’s appeal. The Supreme Court reversed, holding that the testator intended to create a discretionary, supplemental needs trust and, therefore, the trust corpus and income may not be considered to be available to Plaintiff for the purpose of determining eligibility for Medicaid benefits. View "Pikula v. Dep’t of Social Servs." on Justia Law

Plaintiffs, a married couple proceeding as self-represented parties, commenced a legal malpractice action against Defendants by way of a complaint and a summons. Defendants filed a motion to dismiss the complaint on the ground that the writ of summons failed to provide either a recognizance by a third party or a certification of Plaintiffs’ financial responsibility. The trial court granted the motion and dismissed the action. The Appellate Court summarily affirmed the judgment of dismissal. The Supreme Court reversed, holding that the trial court abused its discretion by failing to afford Plaintiffs an opportunity to file a bond to avoid dismissal of the action. Remanded. View "Costello v. Goldstein & Peck, P.C." on Justia Law

Plaintiff, a former smoker and cancer survivor, brought an action in federal district court against R.J. Reynolds Tobacco Company pursuant to Connecticut’s Product Liability Act under theories of strict liability and negligent design. At trial, evidence was presented that Defendant purposefully manufactured cigarettes to increase daily consumption without regard to the resultant increase in exposure to carcinogens. After a jury trial, the district court rendered judgment in Plaintiff’s favor. Defendant appealed to the Second Circuit Court of Appeals, claiming that Plaintiff’s product liability cause of action was foreclosed by comment (i) to section 402A of the Restatement (Second), Torts because comment (i) precludes liability of a seller of good tobacco. The Second Court certified to the Supreme Court a question of law regarding the preclusive effect of comment (i) on a strict product liability claim. The Supreme Court held (1) the modified consumer expectation test is the Court’s primary strict product liability test and the sole test applicable to this case; and (2) because the obvious danger exceptions to strict liability in comment (i), including “[g]ood tobacco,” are not dispositive under the multifactor modified consumer expectation test, comment (i) did not preclude a lawsuit in this case. View "Izzarelli v. R.J. Reynolds Tobacco Co." on Justia Law

After a jury trial, Defendant was convicted of both intentional and reckless assault in the first degree. Defendant filed a motion for a new trial, arguing that the convictions were legally inconsistent. The trial court denied the motion. The Appellate Court reversed, concluding that Defendant’s convictions for intentional and reckless assault were legally inconsistent. The Supreme Court reversed, holding (1) Defendant’s convictions were not legally inconsistent under the State’s argument that the assault occurred in two reckless and intentional phases, respectively; and (2) Defendant had sufficient notice that he could be convicted of both reckless and intentional assault, and therefore, the manner in which Defendant was convicted satisfied the requirements of due process. View "State v. King" on Justia Law

Petitioner was convicted of sexual assault in the first degree and kidnapping in the first degree. Thereafter, in State v. Salamon and Luurtsema v. Comm’r of Corr. (Luurtsema II), the Supreme Court overruled its overly broad interpretation of its kidnapping statutes and determined the holding in Salamon applied retroactively to collateral attacks on final judgments. Petitioner subsequently filed a second petition for a writ of habeas corpus arguing that there was constitutional error in the kidnapping instruction pursuant to Salamon and Luurtsema II. The habeas court granted a new trial on the kidnapping charge and rejected the Commissioner of Correction’s assertion that Petitioner’s failure to challenge the Court’s long-standing interpretation of kidnapping in his criminal proceedings led to his procedural default. The Appellate Court affirmed. The Supreme Court affirmed, holding (1) Luurtsema II’s retroactivity decision compels the conclusion that challenges to kidnapping instructions in criminal proceedings rendered final before Salamon are not subject to the procedural default rule; and (2) Petitioner was entitled to a new trial on the kidnapping charge because the omission of a Salamon instruction was not harmless beyond a reasonable doubt. View "Hinds v. Comm’r of Corr." on Justia Law

Plaintiff was the homeowner’s association for a common interest community. Defendant owned a condominium unit in the community. Pursuant to a "standard collection policy" adopted by Plaintiff in 2011, Plaintiff brought this action seeking to foreclose a statutory lien for allegedly delinquent common expenses, attorney’s fees, and costs. Defendant moved to dismiss the complaint on the ground that the court lacked subject matter jurisdiction due to Plaintiff’s failure to vote to commence a foreclosure action against Defendant’s unit or to adopt a standard foreclosure policy pursuant to the notice and comment requirements of Connecticut’s Common Interest Ownership Act. Plaintiff, in turn, argued that its policy was an "internal business operating procedure" rather than a rule and therefore was not subject to the notice and comment procedures for rules. The trial court entered judgment in favor of Plaintiff, concluding that Plaintiff’s standard foreclosure policy was an internal business operating procedure, not a rule. The Supreme Court reversed, holding that the standard foreclosure policy is a rule and that the rule-making requirements are jurisdictional. Remanded with direction to dismiss Plaintiff’s action. View "Neighborhood Ass’n v. Limberger" on Justia Law

Plaintiff allegedly suffered heart problems and psychological injuries during the course of his employment with Defendant, FedEx. The Workers’ Compensation Commissioner found that Plaintiff’s physical and psychological injuries were compensable and awarded him total incapacity benefits covering a period of forty-seven weeks. The Workers’ Compensation Review Board upheld the Commissioner’s findings and award. The Supreme Court affirmed, holding (1) the Board properly upheld the Commissioner’s determination that both Plaintiff’s physical and psychological injuries were compensable under the Workers’ Compensation Act; and (2) the Commissioner’s award was not excessive. View "Hart v. Federal Express Corp." on Justia Law