Justia Connecticut Supreme Court Opinion Summaries

Plaintiffs, retired police officers and firefighters for the City of Meriden, sought a writ of mandamus prohibiting the City from imposing a “cost share” requirement on them mandating that they pay a certain percentage of their health insurance, thereby reducing their health insurance emoluments. The trial court rendered judgment for the City, concluding that the City properly reduced Plaintiffs’ health insurance emoluments in 2005 according to the terms of a provision in a prior version of the Meriden City Charter and a related stipulated judgment. The Supreme Court affirmed, holding that the trial court did not err in (1) interpreting the city charter provision and stipulated judgment as allowing the City to impose the cost share requirement on Plaintiffs; (2) excluding certain evidence regarding collective bargaining agreements that precipitated the reduction in Plaintiffs’ benefits; and (3) declining to take judicial notice of Conn. Gen. Stat. 7-450c in interpreting the terms of the City’s pension plan because Plaintiffs had not pleaded a violation of that statute in their amended agreement. View "Awdziewicz v. Meriden" on Justia Law

Petitioner entered a plea of nolo contendere to felony murder and related crimes. Petitioner was sixteen years old when he committed the crimes. The trial court sentenced Petitioner to a total effective prison term of fifty years with no possibility of parole. After Petitioner’s conviction and sentence became final, the U.S. Supreme Court decided Miller v. Alabama. Petitioner filed a petition for a writ of habeas corpus arguing that the statutory authority under which his fifty year prison term with no possibility of parole was imposed violated the Eighth Amendment as applied to him. The habeas court granted summary judgment for the State, concluding that Miller did not apply to Petitioner’s sentence. The Supreme Court reversed, holding (1) Miller applies retroactively under Connecticut law to cases arising on collateral review; and (2) Miller applies to the imposition of a fifty year sentence on a juvenile offender. Remanded. View "Casiano v. Comm’r of Corr." on Justia Law

Recall Total Information Management, Inc. (Recall) contracted with IBM to transport and store computer tapes containing personal information of IBM employees. Recall subcontracted with Executive Logistics Services, LLC (Ex Log) to provide transportation services for the tapes. In connection with the agreements, Federal Insurance Company (Federal) issued a commercial general liability policy and Scottsdale Insurance Company (Scottsdale) issued an umbrella liability policy to Ex Log. Both policies named Recall as an additional insured. When Ex Log lost the computer tapes, IBM spent large sums providing identity theft services. In informal negotiations, IBM sought reimbursement of those sums from Recall and Ex Log (together, Plaintiffs). Defendants - Federal and Scottsdale - refused to participate in the negotiations or to provide coverage to Plaintiffs under the policies. Plaintiffs commenced this action alleging breach of the insurance contracts. The trial court rendered summary judgment in favor of Defendants. The Appellate Court affirmed. The Supreme Court affirmed, holding that the Appellate Court did not err in concluding that (1) Defendants did not waive coverage defenses by breaching their duty to defend Plaintiffs in settlement negotiations; and (2) the policy provisions at issue did not afford coverage for claims made against Plaintiffs by a third party. View "Recall Total Info. Mmgt., Inc. v. Fed. Ins. Co." on Justia Law

At the time that Claimant suffered a compensable work-related injury to his left knee, Liberty Mutual Insurance Group (Liberty Mutual) was the workers’ compensation insurance carrier for Claimant’s employer (Employer). Claimant subsequently suffered a compensable work-related injury to his right knee. At the time, Chubb & Son (Chubb) was the workers’ compensation insurance carrier for Employer. Claimant was scheduled to have bilateral knee replacement surgery, but the two insurance carriers disagreed about who would pay for Claimant’s temporary total disability benefits. After a hearing, the Workers’ Compensation Commissioner required Liberty Mutual to reimburse Chubb for one half of Claimant’s temporary total disability benefits. The Workers’ Compensation Review Board and the Appellate Court affirmed. Liberty Mutual appealed, claiming that the Commissioner lacked the statutory authority to order the reimbursement to Chubb. The Supreme Court affirmed, holding that, given the unique factual circumstances of this case, the Commissioner had the authority to order the reimbursement pursuant to the relapse statute, Conn. Gen. Stat. 31-307b. View "Gill v. Brescome Barton, Inc." on Justia Law

After a jury trial, Defendant was convicted of murder and tampering with physical evidence. Defendant appealed, arguing that the trial court erred in failing to suppress (1) certain oral statements made to police officers after his apprehension on the ground that the statements were the result of a custodial interrogation without his having been read his Miranda warnings, and (2) a statement he made after being given his Miranda warnings on the ground that it was the product of coercion. The Supreme Court affirmed, holding that the trial court properly denied Defendant’s motion to suppress, as (1) Defendant was not subjected to custodial interrogation before receiving the Miranda warnings; and (2) Defendant’s confession was made voluntarily. View "State v. Ramos" on Justia Law

After a jury trial, Defendant was convicted of carrying a pistol without a permit, having a weapon in a motor vehicle with a permit, and possession of an assault weapon. The Appellate Court affirmed. Defendant appealed, arguing that the Appellate Court erred in concluding that the trial court properly rejected Defendant’s claim under Conn. Gen. Stat. 54-1c that he was entitled to the suppression of his written confession that he had given to the police following his arrest because he was not presented to the first session of the court. The Supreme Court affirmed, holding (1) section 54-1c did not bar the State’s use of Defendant’s written statement because section 54-1c is inapplicable when, as in this case, the statement is elicited prior to the expiration of the first session of court, when the defendant’s presentment still would have been timely; and (2) the evidence was sufficient to establish that Defendant had carried a pistol in violation of Conn. Gen. Stat. 29-35(a). View "State v. Crespo" on Justia Law

After Defendant, the owner of real property in the Town of Canton, abandoned the subject property, the Town filed a petition seeking the appointment of a receiver of rents. The trial court, finding that Defendant owed the Town taxes, granted the petition and authorized the receiver to collect all rents or use and occupancy payments. The court subsequently modified its order to allow the receiver to evict the tenant and to bring an action against the tenant for all rents due. The tenant moved to remove the receiver, asserting that the receiver had exceeded its authority under Conn. Gen. Stat. 12-163a by serving it with a notice to quit and by bring an action to collect back taxes and prior rents. The court denied the motion for removal. The Appellate Court (1) reversed insofar as the trial court granted the receiver’s motion to modify the receivership orders, but (2) affirmed insofar as it denied the tenant’s motion to remove the receiver. The Supreme Court (1) reversed as to the reversal of the trial court’s judgment granting the receiver’s motion for modification, holding that section 12-163a does authorize a receiver to use legal process to collect rent due prior to the date of the receiver’s appointment; and (2) otherwise affirmed. View "Canton v. Cadle Props. of Conn., Inc." on Justia Law

Plaintiffs and their older brother, Kenneth Stuart, Jr. (Kenneth) were the children of Kenneth Stuart, Sr. (Stuart). When Stuart died, Plaintiffs filed a complaint alleging that Kenneth, who became an estate fiduciary, unduly influenced Stuart and breached numerous fiduciary duties owed to them as estate beneficiaries. Throughout much of Plaintiffs’ litigation against Kenneth, Kenneth engaged Defendant as a certified public accountant. Ultimately, the trial judge ruled against Kenneth and awarded monetary damages to Stuart’s estate. Plaintiffs then commenced the present action against Defendant alleging that Defendant prepared inaccurate and misleading financial statements that facilitated the misappropriation of estate funds by Kenneth. The trial court granted summary judgment in favor of Defendant. The Appellate Division reversed in part and remanded. The Supreme Court reversed, holding that Plaintiffs, in objecting to summary judgment, did not present sufficient counterevidence of their reliance on Defendant’s financial statements or a casual connection between his financial statements and their alleged injuries, as was necessary to demonstrate that a genuine issue of material fact existed on the counts of fraud, negligent misrepresentation, and accounting malpractice. View "Stuart v. Freiberg" on Justia Law

The named plaintiff in this case (Plaintiff) obtained a judgment in her favor against Defendants arising out of their medical malpractice. The Supreme Court concluded that the trial court had applied the wrong legal standard in concluding that Plaintiff was not entitled to postjudgment interest and remanded the case to the trial court for consideration of Plaintiff’s request for postjudgment interest under the correct legal standard. Thereafter, the trial court awarded Plaintiff postjudgment interest in the amount of $3,178,696. The Supreme Court reversed in part the order of the trial court, holding (1) the trial court, in awarding eight percent interest on the underlying judgment, did not err in considering the rate of return on certain investments Plaintiff claimed she would have earned if the judgment had been satisfied in a timely manner; but (2) the trial court improperly awarded such interest from October 28, 2010, the date on which the judgment was satisfied, rather than from November 5, 2013, the date on which the trial court awarded postjudgment interest. View "DiLieto v. County Obstetrics & Gynecology Group, P.C." on Justia Law

After a jury trial, Petitioner was found guilty of murder and carrying a pistol without a permit. The Appellate Court affirmed on direct appeal. Thereafter, Petitioner collaterally attacked his conviction by filing a petition for a writ of habeas corpus, claiming that his trial attorney had rendered ineffective assistance of counsel. The habeas court denied the habeas petition. On appeal, Petitioner raised for the first time a new theory as to why his attorney had rendered ineffective assistance. The Appellate Court declined to review Petitioner’s claim on the grounds that that review under State v. Golding is not available for unpreserved claims of error raised for the first time in a habeas appeal. The Supreme Court affirmed, holding that Golding review was unavailable for Petitioner’s ineffective assistance claim because that claim did not arise out of the actions or omissions of the habeas court itself. View "Moye v. Comm’r of Corr." on Justia Law