Justia Connecticut Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of illegal possession of an explosive and manufacturing a bomb. The Appellate Court reversed in part the judgment of the trial court, concluding that the trial court committed plain error by not providing an accomplice credibility instruction, sua sponte, to the jury. The Supreme Court reversed in part the judgment of the Appellate Court, holding (1) the trial court’s failure to give an accomplice credibility instruction did not constitute plain error; and (2) it is unnecessary to reach the merits of Defendant’s alternative ground for affirmance, namely, that the trial court violated Defendant's constitutional rights by compelling him to provide a handwriting exemplar, as any alleged error was harmless. View "State v. Jamison" on Justia Law

After a jury trial, Defendant was convicted in two consolidated cases of attempted murder, two counts of risk of injury to a child, and murder. The Supreme Court reversed, concluding that the trial court improperly granted the State’s motion to disqualify his chosen attorney, Gary Mastronardi, and that the improper disqualification was structural error requiring a new trial. On remand, Defendant filed a motion asking the State to fund Mastronardi’s private fee or, alternatively, to dismiss the charges against him on the grounds that he was now indigent and tat Mastronardi would not represent him at the new trial at the rate paid to assigned counsel by the Division of Public Defender Services. The trial court denied Defendant’s motion, concluding that the Supreme Court’s decision Peeler I did not require it. After a second jury trial, Defendant was found guilty on all counts. The Supreme Court affirmed, holding that the trial court did not violate Defendant’s right to counsel of choice at his new trial by denying his funding motion. View "State v. Peeler" on Justia Law

Plaintiffs, a partnership and an LLC, were related entities with common owners. The partnership acquired a commercial office complex and later transferred ownership of the property to the LLC. In 2008, the City of Norwalk’s tax assessor set the fair market value of the partnership at approximately $49 million. The trial court sustained Plaintiffs’ property tax appeal and reduced the valuation of the LLC’s property by approximately $15 million. The Appellate Court reversed, concluding that the trial court lacked subject matter jurisdiction over Plaintiffs’ appeal because the LLC had not appeared in administrative proceedings before the City’s Board of Assessment Appeals and did not initiate the appeal to the trial court. The Supreme Court reversed, holding that although the tax appeal was initially brought by a nonaggrieved party, the partnership, the appeal was also maintained by the LLC, an aggrieved party that had properly been added to the trial court proceedings by way of a promptly filed amended complaint. View "Fairfield Merrittview Ltd. P’ship v. City of Norwalk" on Justia Law

The predecessors of Plaintiff and Defendants entered into a right-of-way agreement that created an express easement for the benefit of property owned by Plaintiff over a driveway located on the property owned by Defendants. Plaintiff commenced this action asserting a quiet title claim and a claim seeking an injunction restoring Plaintiff’s rights under the agreement. Defendants raised special defenses, asserting that Plaintiff’s property had been used for purposes other than “professional offices or residential uses” in violation of the terms of the agreement. The trial court entered judgment for Defendants, concluding that the easement was in effect until Plaintiff’s property was used by a mortgage brokerage, a home health-care agency, and an appliance delivery coordination service, which tenancies terminated the agreement. The Appellate Court affirmed. The Supreme Court reversed, holding (1) the Appellate Court improperly concluded that the term “professional offices,” as used in the agreement, was plain an unambiguous; and (2) using the broader definition of the term “professional” indicates that the agreement did not preclude offices of the type that had been previously operated out of Plaintiff’s property. Remanded. View "NPC Offices, LLC v. Kowaleski" on Justia Law

After a jury trial, Defendant was convicted of crimes committing during a string of armed robberies in the cities of Stamford and Norwalk and the town of Greenwich. Defendant appealed, arguing (1) his constitutional right to counsel was violated when the trial court admitted incriminating statements he made regarding the Norwalk and Greenwich robberies while he was represented by counsel in the case involving the Stamford robbery; and (2) the trial court violated his constitutional right to confrontation by restricting defense counsel’s cross-examination of a key prosecution witness. The Supreme Court affirmed, holding that the trial court’s admission of the incriminating statements and its restrictions on counsel’s cross-examination of the witness did not violate Defendant’s Sixth Amendment rights or constitute an abuse of discretion. View "State v. Leconte" on Justia Law

In 2002, the marriage of Beverly Studer and John Studer was dissolved in Florida. In 2003, John moved in Connecticut Superior Court to modify the amount of his child support and alimony obligations. The superior court granted the judgment. In 2010, Beverly filed two postjudgment motions for postmajority support for the parties’ child, who had autism. The trial court granted the motions and ordered John to pay child support indefinitely, concluding that Florida law controlled the duration of John’s child support obligation. The Supreme Court affirmed, holding that because Florida was the first state to enter a child support order in the present case, the trial court did not err in concluding that Florida law governed the duration of John’s child support obligation. View "Studer v. Studer" on Justia Law

In 2013, the legislature amended the statutes governing Connecticut’s public land records system to create a two-tiered system in which a nominee of a mortgagee operating a national electronic database to track residential mortgage loans must pay substantially more in recording fees than do other mortgagees. Mortgage Electronic Registration Systems, Inc. and MERSCORP Holdings, Inc. (collectively, Plaintiffs), the only entities currently required to pay the increased recording fees, brought this action against Defendants - the governor, attorney general, treasurer, state librarian, and state public records administrator - seeking injunctive relief and a judgment declaring that this two-tiered fee structure violates various provisions of the federal and state constitutions. The trial court granted summary judgment in favor of Defendants. The Supreme Court affirmed, holding that the fees do not violate the equal protection guarantees of the state and federal constitutions or the dormant commerce clause of the federal constitution. View "MERSCORP Holdings, Inc. v. Malloy" on Justia Law

Defendant filed an application to be exempted from continued registration as a sex offender pursuant to Conn. Gen. Stat. 54-251(b). Following contested hearings, the trial court exempted Defendant from the continued obligation to register as a sex offender, finding that Defendant was under nineteen years of age at the time of the offense and that registration was not required for public safety. The State appealed, and the Appellate Court affirmed. The Supreme Court affirmed, holding that the Appellate Court properly concluded that the trial court had the authority to grant Defendant’s application for an exemption from registration approximately seven years after he had commenced registration, notwithstanding his agreement to register as a sex offender for ten years in his plea agreement with the State. View "State v. Obas" on Justia Law

Defendant was convicted of murder, assault in the first degree, criminal possession of a pistol, and risk of injury to a child. Defendant appealed, arguing that the trial court abused its discretion in failing to conduct an inquiry into his claim of juror misconduct. The Supreme Court reversed and remanded with instructions for the trial court to conduct an inquiry into Defendant’s claim. After approximately a decade, the trial court held the required inquiry and found no evidence of juror misconduct. The Supreme Court affirmed, holding (1) the trial court did not err in concluding that there was no evidence of juror misconduct; and (2) the delay on remand did not violate Defendant’s due process rights. View "State v. Roman" on Justia Law

In 2009, Wheelabrator Bridgeport, L.P., which operates a waste to energy facility in the city of Bridgeport, appealed from the tax assessment of the City, alleging that the city had overvalued the property on the city’s 2007 and 2008 grand lists. In 2011, Wheelabrator and other plaintiffs filed a second appeal from the city’s tax assessment, alleging that the city had overvalued the property on the 2010 grand list. The two appeals were consolidated for purposes of trial. The trial court dismissed the first appeal for lack of standing and then rendered partial judgment in favor of Wheelabrator in the second appeal. The Supreme Court reversed, holding (1) the trial court improperly dismissed the first appeal; and (2) the trial court improperly valued the property in the second appeal and failed to consider evidence of the city’s wrongful conduct in the second appeal. Remanded for further proceedings in the first appeal and a new trial in the second appeal. View "Wheelabrator Bridgeport, L.P. v. Bridgeport" on Justia Law