Justia Connecticut Supreme Court Opinion Summaries

The case involves a group of former firefighters who retired from the city of Meriden and claimed damages from the city and the Meriden Municipal Pension Board for alleged breach of a collective bargaining agreement. The plaintiffs, who retired in 2015, claimed that they should have received an increase in their pension benefits based on a 2% wage increase that was awarded retroactively in an arbitration process after the plaintiffs had retired. The trial court ruled in favor of the plaintiffs, holding that the defendants had breached the collective bargaining agreement by failing to recalculate the plaintiffs' pension benefits based on the retroactive wage increase.On appeal, the Connecticut Supreme Court reversed the trial court's decision. The Supreme Court held that the defendants did not breach the collective bargaining agreement. This conclusion was based on the fact that the pension plan did not allow for the recalculation of pension benefits for retirees who voluntarily retired before the issuance of the arbitration award. The court noted that the pension plan only allowed for a retroactive adjustment of pension benefits for those who were forced to retire due to reaching the mandatory retirement age of 65. The court also held that the trial court did not lack subject matter jurisdiction to hear the case, rejecting the defendants' claim that the plaintiffs failed to exhaust their administrative remedies before filing the lawsuit. View "Stiegler v. Meriden" on Justia Law

The case involves a defendant who was convicted, after a jury trial, of burglary in the first degree, criminal mischief in the first degree, and threatening in the second degree, among other crimes. The defendant had unlawfully entered his brother's residence and caused significant damage within it. Upon appeal, the defendant argued that the trial court had committed plain error by not identifying the specific crime or crimes he allegedly intended to commit when he entered the residence during the jury instruction on first-degree burglary.However, the Supreme Court of Connecticut held that the Appellate Court correctly concluded that the trial court had not committed plain error. The trial court's instruction accurately recited the elements of the burglary charge and clarified that the intent to commit a crime within the building is a distinct element. Furthermore, the court noted that although it is the better practice for trial courts to name the crime or crimes and define such elements in its instructions, it has never been clearly held to be mandatory.Additionally, the court found that even if there was a patent error in the court’s instruction, the omission did not result in a manifest injustice. The evidence presented at trial established that the defendant had violently forced his way into the residence and caused extensive damage, which satisfied the intent element. View "State v. Kyle A." on Justia Law

In this Connecticut case, the plaintiff, Erin C. Hassett, purchased a used motor vehicle from the defendant, Secor’s Auto Center, Inc., and experienced mechanical problems shortly after the purchase. The plaintiff claimed the defendant breached its warranty by refusing to make necessary repairs and, as a result, she revoked her acceptance of the vehicle. The plaintiff brought legal action against the defendant, alleging breach of warranty and revocation of acceptance under statute § 42a-2608. The jury found in favor of the plaintiff, including on her revocation of acceptance claim, awarding her $11,000 in damages.The plaintiff then moved for additur, requesting a refund of the full purchase price of the vehicle in addition to the $11,000 award. The trial court denied the motion, and the Appellate Court upheld the trial court’s decision. The plaintiff appealed to the Supreme Court of Connecticut, arguing that she was entitled to the $11,000 award plus a refund of the full purchase price because the jury found in her favor on her revocation of acceptance claim.The Supreme Court affirmed the Appellate Court’s decision, concluding that the trial court had not abused its discretion in denying the plaintiff’s motion for additur. The court found that the issue of revocation of acceptance damages had been submitted to the jury as a matter of disputed fact. The jury's award of $11,000 was determined to represent revocation of acceptance damages equivalent to its determination of "so much of the price as had been paid" in accordance with § 42a-2-711 (1). The plaintiff's argument that the court should have determined the proper measure of revocation of acceptance damages post-verdict was rejected. The court found that the plaintiff's dissatisfaction with the verdict did not constitute grounds to award her the full purchase price of the vehicle as a matter of law. View "Hassett v. Secor's Auto Center, Inc." on Justia Law

In this case, a petitioner who had been convicted of various larceny offenses filed a petition for a writ of habeas corpus after exhausting his direct appeals. The petition was denied, and the judgment became final on May 9, 2012. Nine days before the judgment in that habeas action became final, the petitioner filed a petition for a writ of habeas corpus in federal court. The federal habeas matter became final in June, 2015. On May 18, 2017, the petitioner filed a second habeas petition in the Superior Court challenging the conviction that was the subject of his first state habeas petition. The respondent, the Commissioner of Correction, requested that the habeas court issue an order directing the petitioner to show good cause why his second state habeas petition should not be dismissed pursuant to § 52-470 (e), claiming that it was filed after the applicable deadline in § 52-470 (d) of October 1, 2014. The habeas court issued an order to show cause for the delay. At an evidentiary hearing on the order to show cause, the petitioner’s counsel argued that the term ‘‘prior petition’’ in § 52-470 (d) was not limited to habeas petitions filed in state court and, therefore, the second state habeas petition was timely because it was filed within two years of the final judgment rendered in connection with the petitioner’s federal habeas petition. The habeas court dismissed the petition, concluding that it was untimely filed and that the petitioner had not established good cause to excuse the delay. The petitioner appealed to the Appellate Court, which affirmed the habeas court’s judgment.The Supreme Court of Connecticut held that the term "prior petition" in § 52-470 (d) unambiguously refers solely to prior state habeas petitions and does not also include prior federal habeas petitions. Therefore, the petitioner’s second state habeas petition was untimely. The court also held that the habeas court properly exercised its discretion in determining that the petitioner had failed to establish good cause for the untimely filing of his second state habeas petition and properly dismissed that petition pursuant to § 52-470 (d) and (e). The petitioner’s claim that good cause existed because he was unaware of § 52-470 and its statutory deadlines when he filed the second state habeas petition was unavailing, as the petitioner’s lack of knowledge of the law, standing alone, was insufficient to excuse his late filing. The judgment of the Appellate Court was affirmed. View "Felder v. Commissioner of Correction" on Justia Law

In the dispute over two slates of candidates each purporting to be the endorsed slate of the Independent Party of Danbury for various municipal offices in the city of Danbury, the Connecticut Supreme Court held that a town clerk has a ministerial obligation to accept and file with the Secretary of State's office lists of minor party candidates that are facially valid under the terms of the state statute. The court found that the town clerk exceeded her authority by failing to file a slate of candidates approved at an Independent Party meeting, and the court should have ordered the clerk to forward that slate to the Secretary of State's office. However, the court also held that the town clerk properly filed a slate of candidates approved at a different Independent Party meeting because the submission of that slate complied with the certification requirement of the state statute. The court concluded that, given the ministerial role of the town clerk, she had no choice but to accept and transmit to the secretary both filings purporting to be the endorsements of the Independent Party, since both were facially compliant with the governing statutes. The court affirmed the trial court's judgment that neither set of endorsements should be placed on the ballot. View "Alves v. Giegler" on Justia Law

The case involves Alico, LLC, a Massachusetts-based company with offices in both Massachusetts and Connecticut. The company's vehicles, used for business, were registered in Massachusetts, and taxes were paid in that state. However, the vehicles were primarily used and garaged in Somers, Connecticut, where the company's sole member and his wife, who also works for the company, reside. In 2018, the tax assessor in Somers, Connecticut, became aware of the presence of these vehicles and retroactively placed them on the town's 2017 and 2018 grand lists, assessing property taxes on them. The plaintiffs, Alico and its sole member, appealed this decision, arguing it was unconstitutional under the dormant commerce clause of the United States constitution. They claimed that because the vehicles were used in interstate commerce and already taxed in Massachusetts, the Connecticut property tax led to impermissible double taxation.The Supreme Court of Connecticut disagreed with the plaintiffs' arguments. The court ruled that the property tax authorized by Connecticut's statute did not violate the dormant commerce clause. The court applied the test set forth in Complete Auto Transit, Inc. v. Brady, which determines the constitutionality of a state tax that is facially neutral but may impose a disproportionate burden on interstate commerce. The court found that the Connecticut tax was applied to an activity with a substantial nexus with the state, was fairly apportioned, did not discriminate against interstate commerce, and was fairly related to the services provided by the state. Therefore, the court affirmed the trial court's denial of the plaintiffs' request for a declaratory judgment declaring the assessments unconstitutional. The court also noted that any double taxation was not the result of a discriminatory tax scheme, but rather the plaintiffs' business decisions. View "Alico, LLC v. Somers" on Justia Law

In the State of Connecticut, the petitioner, who was convicted of felony murder and other crimes, filed a petition for a writ of habeas corpus in 2018, more than five years after his conviction was deemed final. The petitioner initially filed a timely habeas petition in 2012 but withdrew it due to dissatisfaction with his assigned counsel. When filing his 2018 habeas petition, the Commissioner of Correction moved for an order to show cause why the petition should not be dismissed as untimely under § 52-470 (c) and (e). The petitioner argued that good cause existed to excuse the untimely filing since his previous counsel had failed to inform him of the deadline to refile his petition. The habeas court dismissed the 2018 petition as untimely, a decision upheld by the Appellate Court.On appeal to the Supreme Court of Connecticut, the Court reversed the judgment of the Appellate Court, concluding that the habeas court’s determination that no good cause existed was based on a clearly erroneous factual finding. The Court found that the habeas court wrongly assumed that the petitioner's previous counsel had advised him to refile his habeas petition immediately after withdrawing the first one. The Court also clarified that, under the totality of the circumstances, ineffective assistance of counsel can be considered an external, objective factor that could establish good cause to excuse the late filing of a habeas petition under § 52-470 (c) and (e). The case was remanded for a new hearing and a good cause determination under § 52-470 (c) and (e) in light of its factual findings with respect to the performance of prior habeas counsel. View "Rose v. Commissioner of Correction" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of one count of sexual assault in the first degree and two counts of risk of injury to a child, holding that Defendant was not entitled to relief on his claims of error.On appeal, Defendant argued that the State infringed on his right to due process by providing an inadequate notice of intent to offer evidence of other sexual misconduct and that the trial court abused its discretion by admitting the testimony of his daughter concerning sexual misconduct he had engaged in with her fourteen years earlier. The Supreme Court affirmed, holding (1) Defendant had no constitutional right to pretrial notice of other sexual misconduct evidence; and (2) the trial court did not abuse its discretion by admitting evidence of Defendant's other sexual misconduct with his daughter. View "State v. Samuel U." on Justia Law

The Supreme Court reversed the judgment of the trial court in favor of Defendant Barbara Lembo in this action brought by beneficiaries of an inter vivos trust and their mother alleging that Defendant breached her fiduciary duty as trustee, holding that the allegations in the complaint stated a legally sufficient claim for breach of a trustee's fiduciary duties under Connecticut law.The will of the decedent bequeathed the residue of his estate to an amended and restated revocable trust benefitting his three children. At issue was the proper administration of a portion of the decedent's residuary estate that had not yet been distributed to the trust. Plaintiffs brought this action alleging that Defendant, among other things, breached her fiduciary duty by failing to protect and collect trust property. The trial court concluded that Defendant, as a trustee, had no duty to take any action prior to the distribution of the residuary assets. The Supreme Court reversed, holding (1) a genuine issue of material fact remained as to whether Defendant owed the trust beneficiaries a duty to collect and protect the prospective trust property in the residuary estate; and (2) the complaint sufficiently alleged a cause of action against Defendant for breach of her fiduciary duty as trustee. View "Barash v. Lembo" on Justia Law

The Supreme Court affirmed the judgment of the appellate court determining that the State Board of Labor Relations did not act unreasonably, illegally, arbitrarily, or in abuse of its discretion when it applied the clear and unmistakable waiver standard to a union's claim that the town's unilateral change to its pension plan constituted a refusal to bargain collectively in good faith, holding that there was no error.The Town of Middlebury appealed the labor board's determination that the Town violated the Municipal Employee Relations act (MERA), Mass. Gen. Stat. 7-467 et seq., by unilaterally changing the Town's practice of including extra pay duty in calculating pension benefits for members of the Fraternal Order of Police, Middlebury Lodge No. 34. The appellate court concluded that the labor board did not abuse its discretion or act unreasonably, illegally, or arbitrarily when it declined to apply the "contract coverage" standard adopted by the National Labor Relations Board (NLRB) in 2019. The Supreme Court affirmed, holding that it was proper for the appellate court to apply the clear and unmistakable waiver standard, rather than the contract coverage standard, in determining when whether the union had waived its statutory right to bargain collective regarding the manner in which the Town calculated its members' pension benefits. View "Middlebury v. Fraternal Order of Police, Middlebury Lodge No. 34" on Justia Law