Justia Connecticut Supreme Court Opinion Summaries

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

Plaintiffs in these two civil actions were employed in numerous trades at the Kleen Energy power plant construction project in the City of Middletown. Plaintiffs filed this lawsuit against the general contractor of the construction project and other defendants, alleging that Defendants’ negligence caused a gas explosion, which resulted in the termination of Plaintiffs’ gainful employment at the power plant site and economic losses in the form of past and future lost wages. The trial court granted Defendants’ motions to strike the applicable counts of Plaintiffs’ complaints, concluding that Defendants did not owe Plaintiffs a duty of care. Specifically, the trial court determined that “public policy is not served by expanding the defendants’ liability to purely economic claims such as those asserted by the plaintiffs.” The Supreme Court affirmed, holding that the trial court properly granted Defendants’ motions to strike, as Defendants did not owe a duty of care to Plaintiffs, who were employees that sustained only economic losses as a result of the explosion. View "Lawrence v. O & G Indus., Inc." on Justia Law

After a jury trial, Defendant was convicted of two counts of aggravated sexual assault of a minor, in violation of Conn. Gen. Stat. 53a-70c(a)(1) and (6), and other offenses. Defendant sought review pursuant to State v. Golding, claiming that his convictions and sentences for two counts of aggravated sexual assault of a minor violate his right to be free of double jeopardy because they constitute multiple punishments for the same offense. The Supreme Court affirmed, holding that because subdivisions (1) and (6) of section 53a-70c(a) each require proof of a fact that the other does not, and because nothing in either the statutory text or legislative history of the statute reveals a contrary legislative intent, multiple convictions under section 53a-70c for the same transaction do not run afoul of the double jeopardy clause. View "State v. Wright" on Justia Law

Petitioner was convicted of sexual assault in the first degree and risk of injury to a child for sexually abusing a four-year-old girl. Petitioner subsequently filed a petition for a writ of habeas corpus, alleging that his counsel provided ineffective assistance by failing to present expert testimony regarding the suggestibility of young children and the reliability of a child’s recollection of sexual abuse. The habeas court reversed, concluding that Petitioner established that his trial counsel had rendered ineffective assistance. The Appellate Court affirmed. The Supreme Court reversed, holding that the failure of Petitioner’s trial counsel to present the expert testimony was objectively reasonable because there was a legitimate, strategic reason for not presenting such testimony. View "Michael T. v. Comm’r of Corr." on Justia Law

White Oak Corporation and the Department of Transportation entered into a contract for the reconstruction of a bridge and a portion of Interstate 95 in the City of Bridgeport. The project experienced significant delays such that the Department and White Oak reassigned the contract to another contractor for completion. White Oak subsequently filed a notice of claim and demand for arbitration seeking compensation for money wrongfully withheld by the Department, as liquidated damages, for delays in the project. An arbitration panel concluded that the liquidated damages clause in the parties’ contract was unenforceable, and therefore, White Oak was entitled to a return of nearly $5 million withheld by the Department. The trial court granted White Oak’s application to confirm the arbitration award. The Appellate Court reversed, concluding that the arbitration panel exceeded its authority in rendering an award on White Oak’s claim. The Supreme Court reversed, holding that the Appellate Court incorrectly determined that, in a prior action brought by the Department to enjoin the arbitration, the trial court limited the scope of the arbitrable issues in the present case to a claim of wrongful termination such that the arbitration panel lacked jurisdiction to decide White Oak’s liquidated damages claim. View "Dep’t of Transp. v. White Oak Corp." on Justia Law

Pursuant to a plea agreement, Petitioner pleaded guilty to manslaughter in the first degree with a firearm. The plea agreement stated that Petitioner would receive a total sentence of between twenty and twenty-five years’ imprisonment and that defense counsel had a right to argue for a sentence beneath the twenty-five year cap. At sentencing, defense counsel agreed with the prosecutor’s recommendation that the trial court should impose the maximum sentence under the agreement. The trial court sentenced Petitioner to twenty-five years imprisonment. Petitioner subsequently filed a petition for a writ of habeas corpus, claiming ineffective assistance of counsel. The habeas court denied relief, determining that Petitioner failed to prove ineffective assistance of counsel under Strickland v. Washington. The Appellate Court affirmed, concluding that the habeas court properly determined that Petitioner failed to prove actual prejudice under Strickland. The Supreme Court reversed in part, holding that the habeas court improperly applied Strickland to Petitioner’s ineffective assistance claim because a complete breakdown in the adversarial process occurred, and therefore, Petitioner’s claim was instead controlled by United States v. Cronic, under which prejudice should be presumed. View "Davis v. Comm’r of Corr." on Justia Law

Plaintiff filed an ex parte restraining order application against Defendant and requested a hearing on the application. The trial court denied Plaintiff’s application and request for a hearing. Plaintiff subsequently filed a second application for a restraining order. The trial court also denied this application without a hearing. Plaintiff filed an appeal with the Appellate Court and an application for certification to appeal pursuant to Conn. Gen. Stat. 52-265a. The Supreme Court granted the section 52-265a application. The trial court then held a hearing on the applications. The applications were denied after the hearing. Thereafter, the Supreme Court ordered the parties to address whether Plaintiff’s appeals were moot. The Supreme Court subsequently dismissed the appeals for lack of subject matter jurisdiction, holding that there was no practical relief the Court could afford Plaintiff, and this case did not meet the capable of repetition yet evading review exception to the mootness doctrine. View "Wendy V. v. Santiago" on Justia Law

After a jury trial, Defendant was found guilty of larceny in the third degree. The State sought to have Defendant’s sentence enhanced under Conn. Gen. Stat. 53a-40b because Defendant had committed the larceny while he was released on bond. Prior to the hearing on the sentence enhancement, the records for Defendant’s previous arrests had been erased in accordance with Conn. Gen. Stat. 54-142a. The trial court allowed the State to introduce those records into evidence and, relying solely on those records, found that Defendant had committed the larceny while he was on release. The Appellate Court reversed, concluding that the trial court had improperly allowed the State to introduce the erased records and that the State could not seek to prove the basis for the sentence enhancement at a new hearing. The Supreme Court reversed in part, holding (1) the trial court improperly permitted the State to introduce the erased records to prove the basis for the sentence enhancement under section 53a-40b; but (2) on remand, the State is not foreclosed from seeking to establish the basis for Defendant’s sentence enhancement by use of evidence other than the erased records. View "State v. Apt" on Justia Law

When thirty-one-year-old Bill Smolinski disappeared, Defendants, Bill’s mother and sister, began to pressure Plaintiff, Bill’s former girlfriend, into cooperating with the investigation by saying disparaging things to Plaintiff’s acquaintances and posting missing person flyers depicting Bill along Plaintiff’s school bus route and near her home. Plaintiff brought this action claiming defamation and intentional infliction of emotional distress. The trial court entered judgment awarding Plaintiff compensatory and punitive damages on her claims. The Appellate Court affirmed. The Supreme Court reversed and remanded for a new trial, holding that the trial court’s findings on Plaintiff’s claims of defamation and intentional infliction of emotional distress did not consider - and were not consistent with - the First Amendment limitations placed on these torts. View "Gleason v. Smolinski" on Justia Law

Kleen Energy Systems, LLC, an electric generating facility, entered into a contract with Connecticut Light and Power Company, an electric distribution company. A dispute subsequently arose concerning the proper interpretation of the contract’s pricing provision. At the request of Waterside Power, LLC, which had entered into a similar contract with Connecticut Light and Power, the Commissioner of Energy and Environmental Protection, acting through the Public Utilities Regulatory Authority (the Authority), conducted proceedings to resolve the dispute. Kleen Energy was a participant in, but not a party to, those proceedings. Waterside subsequently filed a petition for a declaratory ruling challenging the decision. The Authority issued a declaratory ruling denying Waterside relief. Kleen Energy filed an administrative appeal from the Authority’s ruling, claiming that it had a contractual right to submit the dispute to arbitration and that the Authority lacked jurisdiction to issue a declaratory ruling to resolve the dispute. The trial court ultimately concluded (1) the Authority had jurisdiction to issue a declaratory ruling to resolve the dispute, (2) Kleen Energy had waived its contractual right to arbitration, and (3) the Authority had properly resolved the dispute. The Supreme Court reversed, holding that the trial court erred in determining that the Authority had jurisdiction to resolve the pricing dispute. View "Kleen Energy Sys., LLC v. Comm’r of Energy & Envtl. Prot." on Justia Law