Justia Connecticut Supreme Court Opinion Summaries

Defendant was found not guilty of certain offenses by reason of mental disease or defect and transferred to a maximum security psychiatric facility. Defendant was charged with new, violent crimes while housed at the facility. The trial court set a monetary bond as a condition of release. Because Defendant was unable to post that bond, he was transferred to the custody of the Commissioner of Correction at a prison while awaiting trial on the new charges. Defendant appealed. The Supreme Court affirmed, holding that the trial court’s imposition of a monetary bond and, after Defendant was unable to post that bond, Defendant’s transfer to the custody of the Commissioner, did not violate Defendant’s constitutional rights to (1) bail, pursuant to the Connecticut Constitution; and (2) procedural due process, pursuant to the Fourteenth Amendment to the United States Constitution. View "State v. Anderson" on Justia Law

Plaintiffs brought this action alleging that the towns of Woodbury and Bethlehem held a referendum on the question of whether to approve a resolution by the Board of Education for Regional School District Number 14 authorizing the issuance of bonds and notes to finance school construction expenses without complying with the provisions of Conn. Gen. Stat. 10-56, 10-47c and 9-226 requiring towns to publish warning of a referendum in the same manner as provided for the election of town officials. Plaintiffs contended that this failure rendered the referendum null and void ab initio. Defendants, the towns and the board of education, filed motions to strike Plaintiffs’ claims, which the trial court granted in part. As to the remaining claims, the trial court granted Defendants’ motion for summary judgment and rendered judgment for Defendants. The Supreme Court affirmed, holding (1) Defendants’ failure to comply with the notice provisions of the governing statutes did not automatically require the invalidation of the referendum; and (2) there was no genuine issue of material fact as to whether the results of the referendum were seriously in doubt as the result of Defendants’ failure to properly warn the referendum pursuant to the applicable statute. View "Arras v. Reg’l Sch. Dist. No. 14" on Justia Law

Defendant entered conditional pleas of nolo contendere to possession of a controlled substance with intent to sell, home invasion, robbery in the second degree, burglary in the third degree, a stealing a firearm. Defendant appealed the trial court’s denial of his motion to suppress evidence of statements he made to the police following his arrest, in which he confessed to the charged crimes. Specifically, Defendant argued that his statements should have been suppressed as the product of an illegal search because the warrant authorizing the search of his apartment was unsupported by probable cause. The Appellate Court affirmed. The Supreme Court affirmed, holding that the affidavit in support of the search warrant application established probable cause, and accordingly, the Appellate Court properly affirmed the trial court’s denial of Defendant’s motion to suppress. View "State v. Flores" on Justia Law

This case came to the Supreme Court on certification from the United States District Court for the District of Connecticut. Plaintiff sued his former employer in federal court, alleging, inter alia, that Defendants had violated Conn. Gen. Stat. 31-51q by subjecting him to discipline on account of Plaintiff’s exercise of his rights guaranteed by Conn. Const. art. I, sections 3, 4 or 14. The Supreme Court answered (1) the rule announced by the United States Supreme Court in Garcetti v. Ceballos that when employees make statements pursuant to their official duties the employees are not speaking as citizens for First Amendment purposes and the Constitution does not insulate their communications from employer discipline does not apply to a claim that an employer violated section 31-51q by subjecting an employee to discipline or discharge on account of the exercise by such an employee of rights guaranteed by Conn. Const. art. I, sections 3, 4, or 14; and (2) under the state Constitution, employee speech pursuant to official job duties on certain matters of significant public interest is protected from employer discipline in a public workplace, and section 31-51q extends the same protection to employee speech pursuant to official job duties in the private workplace. View "Trusz v. UBS Realty Investors, LLC" on Justia Law

Plaintiff brought this medical malpractice action against Dennis Rodin and Waterbury Orthopaedic Associates, P.C., alleging that Rodin negligently failed to timely diagnose Plaintiff’s compartment syndrome, resulting in severe injuries to Plaintiff’s lower left leg. The jury returned a verdict in favor of Defendants, and the trial court rendered judgment in accordance with the jury verdict. The Appellate Court affirmed. The Appellate Court affirmed. The Supreme Court affirmed, holding (1) the trial court did not abuse its discretion in restricting Plaintiff’s use of an article from a medical journal to impeach certain witnesses; (2) the trial court did not abuse its discretion in precluding Plaintiff from questioning Defendants’ expert witness about his previous experience as an expert on behalf of Rodin; and (3) although the trial court should have allowed Plaintiff to make an offer of proof and mark a document for identification in connection with the proffered questioning of Defendants’ expert witness, the improprieties were not harmful to Plaintiff. View "Filippelli v. Saint Mary's Hosp." on Justia Law

The Commissioner of Environmental Protection brought this action against Defendants, auto parts companies, alleging that Defendants had violated Conn. Gen. Stat. 22a-430(a), 22a-430b and 22a-427, which are part of the Water Pollution Control Act. As a remedy, the trial court ordered Defendants to pay certain fines and to retain an environmental professional to assist Defendants in complying with the law, to conduct testing on the site at issue to determine whether a significant environmental hazard exists, and, if so, to abate the condition. The trial court rendered judgment against Defendants. The Supreme Court reversed, holding (1) having found that Defendants had violated the Water Pollution Control Act, the trial court was required to order Defendants to remediate the pollution in accordance with the remediation standards promulgated by the Commissioner, and the court did not have discretion to fashion a remedy that did not purport to do so; and (2) the trial court’s order also constituted an abuse of discretion because it was effectively unenforceable. Remanded for a new trial. View "Comm’r of Envtl. Prot. v. Underpass Auto Parts Co." on Justia Law

The named plaintiff, in her individual capacity and in her capacity as administratrix of the estate of her late husband, and the couple’s three children, brought this action against Defendants, alleging wrongful death and including claims for the children’s loss of parental consortium. Defendants filed a motion to strike the loss of parental consortium claims in accordance with Mendillo v. Board of Education, which the trial court granted. The jury then returned a verdict for the plaintiffs on the remainder of the claims. At issue on appeal was whether the Supreme Court should overrule the holding in Mendillo, in which the Court declined to recognize a derivative cause of action for loss of parental consortium by a minor child. The Court concluded that it should and therefore reversed the judgment with respect to the claims for loss of parental consortium, holding (1) Mendillo’s holding is overruled, and the Court now recognizes a cause of action by a minor child for loss of parental consortium resulting from an injury to a parent, subject to certain limitations; and (2) the holding recognizing a cause of action for loss of parental consortium applies to the present case. View "Campos v. Coleman" on Justia Law

Petitioner was convicted of reckless endangerment in the second degree and related offenses. Petitioner filed a petition for writ of habeas corpus, claiming that his trial counsel rendered ineffective assistance at his criminal trial because she chose not to pursue questioning of a potential exculpatory witness. The habeas court denied the petition. The Appellate Court dismissed Petitioner’s appeal, concluding that substantial evidence supported the habeas court’s conclusion that Petitioner had failed to establish the prejudice prong for ineffective assistance of counsel under Strickland v. Washington. The Supreme Court affirmed, holding that the Appellate Court properly dismissed Petitioner’s appeal on the ground that he had failed to satisfy the prejudice prong of Strickland. View "Staton v. Comm’r of Corr." on Justia Law

After a jury trial, Defendant was found guilty of two counts of sexual assault in the third degree, once count of sexual assault in the fourth degree, and three counts of risk of injury to a child. The Appellate Court reversed Defendant’s conviction and remanded the case for a new trial, concluding that the prosecutor’s statements during closing argument deprived Defendant of his due process right to a fair trial. The Supreme Court reversed the judgment of the Appellate Court, holding that the majority of the challenged remarks were not improper and that the remaining remark did not deprive Defendant of a fair trial. View "State v. Felix R." on Justia Law

In 2005, Landmark Investment Group, LLC entered into a contract with Chung Family Realty Partnership, LLC (Chung, LLC) to purchase certain property. Chung, LLC repudiated the contract after receiving a more attractive offer from CALCO Construction & Development Company (Calco) and John Senese, Calco’s president and owner (together, Defendants). Landmark successfully sued for specific performance of the contract but was unable to purchase the property after it was sold at a foreclosure auction where a company controlled by Senese was the highest bidder. Landmark then filed suit against Defendants, alleging tortious interference with its contractual relations and a violation of the Connecticut Unfair Trade Practices Act (CUTPA). The jury returned a verdict in favor of Landmark on both counts. The trial court, however, granted Defendants’ motion for judgment notwithstanding the verdict (JNOV) and rendered judgment for Defendants. The Supreme Court reversed, holding that the trial court (1) improperly granted Defendants’ motion for JNOV because it failed to view the evidence in the light most favorable to sustaining the jury’s verdict; and (2) incorrectly concluded that Landmark presented insufficient evidence to support its claims. View "Landmark Inv. Group, LLC v. CALCO Constr. & Dev. Co." on Justia Law