Justia Connecticut Supreme Court Opinion Summaries

The present interpleader action arose out of a dispute over the control and ownership of 500 shares of stock in Trikona Advisers Limited, an investment advisory corporation specializing in Indian real estate. Asia Pacific Ventures Limited and Vera Financial Corporation brought an interpleader action to determine ownership of the shares. The trial court rendered an interlocutory judgment of interpleader, ordering that the shares be deposited with the clerk of the court. Haida Investments Limited, the named defendant, appealed. The Supreme Court affirmed, holding (1) Haida established that it was aggrieved by the trial court’s interlocutory judgment of interpleader and therefore had standing to appeal; and (2) the trial court properly rendered an interlocutory judgment of interpleader because Asia Pacific and Vera Financial alleged facts sufficient to establish that Haida had a claim to the shares and that Asia Pacific, Vera Financial, and Haida had facially competing claims to the shares. View "Trikona Advisers Ltd. v. Haida Invs., Ltd." on Justia Law

Santiago G. was born to Mother in 2009 but was cared for since his birth by Maria G, a nonrelative. In 2012, the Commissioner of Children and Families filed a motion for an order of temporary custody of Santiago on the basis of neglect. The trial court adjudicated Santiago neglect on the basis of abandonment by his biological parents. Santiago was subsequently placed in a foster home. Thereafter, the trial court denied the Commissioner’s motion to open and set aside the adjudication of neglect and Respondent’s motion to revoke Santiago’s commitment and disapproved the Department’s permanency plan on placing Santiago with Maria G. The Supreme Court affirmed, holding that although the Department of Homeland Security eventually came to view its initial decisions to pursue removal and custody as unnecessary, that did not render those decisions without a factual basis, and therefore, the Commissioner’s basis for removing Santiago from Maria G.’s care and adjudicating him neglected was not based on a mistake. View "In re Santiago G." on Justia Law

Plaintiff appealed from the Planning and Zoning Commission’s denial of its subdivision permit. Intervenor intervened in the appeal to the trial court pursuant to Conn. Gen. Stat. 22a-19(a), raising claims related to the environmental impact of the proposed development. After remanding the matter back to the Commission for further fact-finding relating to Intervenor’s claims, the trial court set aside the Commission’s findings and adjudicated the factual issues itself. The trial court rendered judgment in favor of Intervenor and forbade Plaintiff’s proposed subdivision from going forward because of its potential environmental impact. The Supreme Court reversed, holding (1) the Environmental Protection Act does not empower a trial court to enter an injunction in an administrative appeal of a zoning decision involving an intervention under section 22a-19; and (2) the trial court could not have properly relied on Conn. Gen. Stat. 22a-18(b) through (d) to remand the matter back to the Commission for consideration of Intervenor’s claims or to independently adjudicate the factual issues raised in those claims. View "Hunter Ridge, LLC v. Planning & Zoning Comm’n" on Justia Law

After a jury trial, Defendant was convicted of first degree assault, first degree unlawful restraint, and carrying a dangerous instrument. Defendant appealed, claiming that his constitutional rights to confrontation, to present a defense and to due process were violated when the trial court disclosed only four pages of the psychiatric records of E.P., a state witness, and prohibited Defendant from consulting with an expert witness as to the four disclosed pages. The Appellate Court affirmed. The Supreme Court affirmed, holding that any error in releasing only four pages of E.P.’s psychiatric records and in limiting Defendant’s ability to consult with an expert as to the disclosed pages was harmless beyond a reasonable doubt. View "State v. Santos" on Justia Law

Defendant was found guilty of capital felony and sentenced to death. While Defendant’s appeal was pending, the legislature passed Public Act 12-5, which repealed the death penalty for all crimes committed on or after April 25, 2012. On June 12, 2012, the Supreme Court affirmed Defendant’s judgment of conviction but reversed his death sentence and remanded for a new penalty phase hearing, concluding that the trial court improperly had failed to disclose to Defendant certain confidential records that were mitigating in nature. Defendant filed a motion for reconsideration, claiming that the adoption of P.A. 12-5 leads to the conclusion that capital punishment has ceased to comport with state constitutional requirements. The Supreme Court agreed and reversed Defendant’s sentence of death on the capital felony count, holding that the enactment of P.A. 12-5, when considered in light of the history of the death penalty in the state and other recent legal developments, compels the conclusion that capital punishment, as currently applied, constitutes cruel and unusual punishment in violation of the constitution of Connecticut. Remanded with direction to sentence Defendant to life imprisonment without the possibility of release. View "State v. Santiago" on Justia Law

Plaintiff, the Town of Stratford, assessed hangars owned by Defendants and located at Sikorsky Memorial Airport as real property. When Defendants contested the classification of the hangars as real property instead of personal property, Plaintiff brought this action seeking a declaratory judgment that the hangars were properly classified as real property and were not exempt from taxation. The trial court ruled that the hangars were taxable as real property pursuant to Conn. Gen. Stat. 12-64(a) and were not exempted pursuant to Conn. Gen. Stat. 12-74. The Supreme Court affirmed, holding that the trial court properly applied sections 12-64 and 12-74 to determine that the hangars were subject to municipal taxation. View "Stratford v. Jacobelli" on Justia Law

After a jury trial, Defendant was convicted of attempt to commit assault in the first degree and various other offenses. The Appellate Court affirmed the judgment of conviction. The Supreme Court affirmed, holding (1) there was sufficient evidence to establish beyond a reasonable doubt Defendant’s intent to inflict serious physical injury on another, as required for a conviction of attempt to commit assault in the first degree; and (2) the Appellate Court properly determined that there was sufficient evidence for a conviction of that offense under a view of the evidence that was fully consistent with the state’s theory at trial. View "State v. Carter" on Justia Law

After a hearing, the trial court terminated the parental rights of Mother as to her two minor children. Mother appealed, arguing that the trial court violated her right to due process when it failed to canvass her about her decision to waive her right to a full trial and to not contest the prosecution’s exhibits. The Appellate Court affirmed, concluding that Mother’s constitutional claim failed under the third prong of State v. Golding. Specifically, the Court concluded that, in order to prevail on an unpreserved claim under Golding, which requires that a party establish that an alleged constitutional violation “clearly exists,” a party must point to binding Connecticut precedent. The Supreme Court reversed, holding (1) the absence of existing Connecticut precedent does not preclude consideration of a claim under Golding; (2) the trial court’s failure to canvass Mother did not constitute a denial of her right to due process; but (3) the Court is warranted in using its supervisory authority over the administration of justice to impose a canvass rule requiring that a trial court canvass all parents who do not consent to the termination immediately before a parental rights termination trial, in order to ensure the overall fairness of the termination of parental rights process. View "In re Yasiel R." on Justia Law

After a jury trial, Defendant was convicted of murder as an accessory and felony murder. On appeal, Defendant argued that the evidence was insufficient to support his conviction of murder as an accessory and that the trial court erred in failing to instruct the jury, sua sponte, on the defense of duress. The Supreme Court affirmed the judgment of the trial court, holding (1) the evidence was sufficient for the jury to find Defendant guilty of murder as an accessory; and (2) the trial court did not improperly fail to instruct the jury, sua sponte, on a defense of duress. View "State v. Bonilla" on Justia Law

After a jury trial, Defendant was convicted of capital felony, murder, and felony murder. The convictions arose from the killing of a single victim. The Appellate Court reversed in part and and remanded the case with direction to vacate Defendant’s convictions of murder and felony murder, concluding that those convictions violated constitutional protections against double jeopardy because they were cumulative of the controlling conviction of capital felony. The State appealed, asserting that vacatur was not the appropriate remedy for Defendant’s cumulative conviction of felony murder that violated his double jeopardy protections. The Supreme Court affirmed, holding that the vacatur remedy set forth in State v. Polanco should extend to scenarios like Defendant’s, thus making it appropriate to vacate his cumulative felony murder conviction. View "State v. Miranda" on Justia Law