Justia Connecticut Supreme Court Opinion Summaries

Decedent entered into a contract for the sale of a parcel of real property to Buyer. Before entering into the contract, Decedent specifically devised the property to Plaintiff, a church, in his will. After Decedent died, a botanical garden and museum claimed entitlement to the proceeds from the sale of the property by the by the coexecutors of Decedent’s estate, due to a charitable pledge made by Decedent prior to his death. The trial court concluded that title to the property passed to Buyer at the signing of the contract under the doctrine of equitable conversion. The appellate court reversed, concluding that equitable conversion did not apply because Decedent died prior to the fulfillment or expiration of a mortgage contingency clause in the contract. The Supreme Court reversed in part, holding that the mortgage contingency clause did not preclude the application of equitable conversion, and equitable title passed to Buyer at the execution of the contract. View "Southport Congregational Church-United Church of Christ v. Hadley" on Justia Law

Defendant executed a promissory note secured by a mortgage and security agreement on Defendant's property. Guarantors guaranteed the note and mortgage. Plaintiff later foreclosed on the property. Thereafter, Plaintiff filed a timely motion seeking a deficiency judgment against Defendant and Guarantors. The trial court found the fair market value of the mortgaged property to be $5.3 million and rendered a deficiency judgment in the amount of $13,264,318. Defendant and Guarantors appealed, arguing that the trial court improperly relied on the appraisal report submitted by the substitute plaintiff and the testimony of Plaintiff’s appraiser because they expressed an opinion on the value of the leased fee interest in the mortgaged property, and Plaintiff was required to establish the value of the fee simple interest. The Supreme Court affirmed, holding that the trial court’s fair market value finding was not erroneous, and Plaintiff satisfied its burden of establishing the value of the mortgaged property. View "J.E. Robert Co. v. Signature Props., LLC" on Justia Law

After a jury trial, Defendant was convicted of assault in the second degree. The Appellate Court reversed, concluding that that Defendant was entitled to a new trial due to certain alleged improprieties that the prosecutor committed during his cross-examination of Defendant and in closing argument. Both parties appealed. The Supreme Court reversed, holding (1) the Appellate Court incorrectly concluded that Defendant was substantially prejudiced by the improprieties at issue in this case; (2) the trial court properly instructed the jury on the initial aggressor exception to self-defense; and (3) the trial court properly denied Defendant’s motion to suppress evidence of the knife that Defendant used during the assault. View "State v. Jones" on Justia Law

Applicant applied for zoning variances allowing for the vertical expansion of a nonconforming building. There was no showing, however, that the strict application of the zoning regulations would destroy the property’s value for any of the uses to which it could reasonably be put. The Zoning Board of Appeals of the Town of Fairfield granted the application, concluding that the strict application of the zoning regulations would produce an unusual hardship. The trial court rejected Plaintiff’s claims and dismissed the appeal. The Supreme Court reversed, holding that the trial court improperly determined that the strict application of the zoning regulations would produce an undue hardship for Applicant, justifying the variances. Remanded to the Board with direction to deny Applicant’s application for the variances. View "E and F Assocs., LLC v. Zoning Bd. of Appeals" on Justia Law

In 2004, Defendant executed a promissory note in favor of Bank that was secured by a mortgage deed on certain property. The mortgage was subsequently assigned to Plaintiff, which was also the holder of the note. In 2012, Plaintiff declared the note to be in default and sought to foreclose on the property. The trial court granted Plaintiff’s motion for entry of default against Defendant for failure to appear and ordered a judgment of foreclosure by sale. Thereafter, Defendant filed a motion to open and vacate the judgment of foreclosure by sale. The trial court denied the motion. Defendant appealed, arguing that the trial court erred in applying Conn. Gen. Stat. 52-12 in denying her motion to open and vacate the judgment of foreclosure by sale and should have applied the standard articulated in Conn. Gen. Stat. 49-15. The Supreme Court dismissed the appeal as moot, holding that even if Plaintiff were to prevail on her claim, the trial court ruled that there was no good cause to warrant the opening of the judgment against her, and therefore, Defendant could be afforded no practical relief if the matter were to be remanded to the trial court. View "JP Morgan Chase Bank, N.A. v. Mendez" on Justia Law

Mother’s minor child (Child) was adjudicated neglected and committed to the care and custody of The Commissioner of Children and Families. Child has been in her current foster placement since 2011. In 2013, the Commissioner petitioned for termination of parental rights on behalf of Child. After a trial, the trial court granted the petition for termination of Mother’s parental rights, finding that the Commissioner had made reasonable efforts toward reunification and that Mother was unable to benefit from the reunification services. The Appellate Court affirmed the judgment of the trial court terminating Mother’s parental rights. The Supreme Court affirmed, holding that there was sufficient evidence to support the trial court’s finding that the Commissioner had proved by clear and convincing evidence that Mother was unable to benefit from reunification services. View "In re Gabriella A." on Justia Law

Michael Aronow, an orthopedic surgeon at the University of Connecticut Health Center, filed a grievance with the Health Center Appeals Committee against Jay Lieberman, the chairman of the orthopedic surgery department at the Center, accusing Lieberman of attempted intimidation and harassment. Aronow requested copies of the Committee’s report of its findings regarding Aronow’s grievance as well as the report written by the president emeritus of the University, but the Center denied Aronow’s request, concluding that the reports were exempt from disclosure pursuant to Conn. Gen. Stat. 10a-154a. The Freedom of Information Commission, however, concluded that the reports were not exempt from disclosure under the statute and ordered the center to provide Aronow with a copy of the reports free of charge. The trial court dismissed Lieberman’s appeal, concluding that the Commission properly determined that the reports did not constitute a “record of the performance and evaluation” of a faculty member under section 10a-154a and were therefore not exempt from disclosure. The Supreme Court affirmed, holding that the reports in this case did not constitute a “record of the performance and evaluation” of a state university faculty or professional staff member within the exemption created by section 10a-154a. View "Lieberman v. Aronow" on Justia Law

Defendant was convicted of possession of narcotics with intent to sell and conspiracy to possess narcotics with intent to sell. The Appellate Court reversed and ordered a new trial, concluding that the prosecutor violated a court order concerning the permissible boundaries of argument and referred to facts outside the record, thus rendering the trial fundamentally unfair. The State appealed, claiming that the prosecutor’s remarks were not improper. The Supreme Court reversed, holding that one of the prosecutor’s arguments was improper, but this improper argument did not deprive Defendant of his due process right to a fair trial because there was no reasonable likelihood that the prosecutor’s comments affected the jury’s verdict. View "State v. Martinez" on Justia Law

An inmate was attacked by another inmate and died from his injuries. Plaintiffs, the victim’s mother and sister, applied for compensation from Defendant, the Office of Victim Services. Defendant declined to compensate Plaintiffs. After a hearing, the Victim Compensation Commissioner denied Plaintiffs’ request for review. Plaintiffs subsequently appealed the Commissioner’s decision. More than four years later, shortly before trial, Defendant moved to dismiss Plaintiffs’ appeal on the ground that it was untimely filed. The trial court dismissed Plaintiffs’ appeal for lack of subject matter jurisdiction, concluding that Plaintiffs did not timely appeal in accordance with Conn. Gen. Stat. 54-211a. The Supreme Court reversed, holding that Plaintiffs satisfied the requirements of section 54-211a by properly serving a writ of summons and a complaint on Defendant within thirty days of the Commissioner’s decision. View "Cales v. Office of Victim Servs." on Justia Law

After a jury trial, Defendant was found guilty of conspiracy to commit assault in the first degree. Defendant appealed, claiming that his exclusion from an in chambers discussion regarding defense counsel’s possible conflict of interest violated his constitutional right to be present at all critical stages of the prosecution. The claim was unpreserved and so Defendant sought review pursuant to State v. Golding. The Appellate Court affirmed the judgment of conviction, determining that the record was inadequate to review the claim. The Supreme Court affirmed, holding that the record, as it presently stood, was not adequate for appellate review. View "State v. Walker" on Justia Law