Justia Civil Rights Opinion Summaries

After he was terminated, Employee sued Employer, alleging, inter alia, disability discrimination. After a trial, the jury trial returned a verdict in favor of Employee and awarded him, inter alia, $500,000 in statutory punitive damages. Employer moved to set aside the award of punitive damages. The trial court granted the motion, determining that Conn. Gen. Stat. 46a-104 does not provide for an award of statutory punitive damages as a remedy for discriminatory practices under the Connecticut Fair Employment Practices Act. The Appellate Court affirmed. The Supreme Court affirmed, holding that section 46a-104 does not authorize punitive damages in employment discrimination cases. View "Tomick v. United Parcel Service, Inc." on Justia Law

At issue in this case was whether, under Connecticut law, after a judgment debtor’s wages have been garnished, the remaining wages are exempt from execution, and whether the transfer of those wages to a third party constitutes a fraudulent transfer. Pursuant to two state court judgments, The Cadle Company was Terry Fletcher’s judgment creditor, Fletcher owing the company more than $3 million. Since at least 2005, Terry has transferred more than $300,000 of his residual wages to the bank account of his wife, Marguerite Fletcher. The Cadle Company sued the Fletchers in federal district court, alleging, inter alia, that the transfer violated the Connecticut Uniform Fraudulent Transfer Act (CUFTA). The district court granted the Fletchers’ motion for partial summary judgment, granted The Cadle Company’s motion for partial summary judgment, and ultimately rendered judgment for The Cadle Company in the amount of $401,426 on its CUFTA claim. The Fletchers appealed to the Second Circuit Court of Appeals. The Second Circuit subsequently certified a question to the Supreme Court, which the Court accepted. The Supreme Court answered that Terry’s residual wages would not have been exempt from execution if he had retained possession of them, and therefore, they were subject to execution after Terry transferred them to his wife’s account. View "Cadle Co. v. Fletcher" on Justia Law

After a jury trial, Defendant was convicted of sexual assault in the first degree and other offenses. The trial court rendered judgment in accordance with the jury’s verdict. The Appellate Court reversed the judgment and remanded the case for a new trial, holding that the State deprived Defendant of his constitutional right to remain silent when the prosecutor noted twice during closing arguments that Defendant had not testified in his own defense. The Supreme Court affirmed, holding (1) the prosecutor’s two statements clearly violated Defendant’s Fifth Amendment right to remain silent; and (2) the State failed to meet its burden of proof that the prosecutor’s comments were harmless beyond a reasonable doubt. View "State v. A. M." on Justia Law

Defendant lived in a unit of a multiunit condominium complex. When the police department received an anonymous tip that Defendant was boasting about growing marijuana in his unit, the police entered the building with a drug dog and conducted a directed search in which the dog sniffed at the common floor hallways and at the bottom of the door to Defendant’s unit. The officers later returned with a search warrant, and Defendant was subsequently arrested and charged with several drug offenses and illegal possession of an assault weapon. Defendant filed a motion to suppress, arguing that the canine sniff of the threshold of his unit for the purpose of investigating the unit’s contents constituted a search within the meaning of article first, section seven of the Connecticut Constitution and the Fourth Amendment of the United States Constitution. The trial court granted the motion to suppress, concluding that the canine sniff constituted a search within the meaning of the Fourth Amendment and, therefore, required a warrant predicated on probable cause. The Supreme Court affirmed, holding that a canine sniff directed toward a home is a search under article first, section seven of the Connecticut Constitution and, as such, requires a warrant issued upon a court’s finding of probable cause. View "State v. Kono" on Justia Law

Defendant was charged with murder and other offenses. In 2010, the trial court found Defendant incompetent to stand trial. Thereafter, a judge found that Defendant had been restored to competency and granted his motion to represent himself. In 2015, the trial court again found Defendant incompetent to stand trial. After evidentiary hearings, the trial court granted the State’s motion for forcible medication of Defendant, finding that the State had established that forced medication would not violate Defendant’s federal due process rights under the test set forth by the United States Supreme Court in Sell v. United States. The Supreme Court affirmed, holding that the trial court correctly determined that forced medication was “substantially likely” to render Defendant competent to stand trial. View "State v. Wang" on Justia Law

Defendant entered a conditional plea of nolo contendere to possession of narcotics with intent to sell and failure to appear in the first degree. Defendant appealed, arguing that the trial court erred in denying Defendant’s motion to suppress narcotics evidence. The appellate court affirmed, concluding (1) the trial court correctly determined that Defendant was not seized until police officers performed a patdown search for weapons, and (2) the record was inadequate to review Defendant’s claim that he was unreasonably seized when two police cruisers descended upon him in a small parking lot and an officer verbally commanded him to stop. The Supreme Court reversed, holding (1) the appellate court erred in concluding that Defendant was not seized until the officers patted him down for weapons and that certain of Defendant's claims in that regard were unreviewable; and (2) the evidence Defendant sought to suppress was seized in violation of the federal and state constitutions. View "State v. Edmonds" on Justia Law

Plaintiff filed a complaint with the Freedom of Information Commission after the Connecticut Resources Recovery Authority (Defendant) failed to promptly produce certain requested communications. Defendant provided some documents to Plaintiff but withheld hundreds of others, asserting that the communications were covered by the attorney-client privilege. A hearing officer recommended that the Commission find that the documents were exempt from disclosure under the attorney-client privilege. Characterizing the communications as containing a mix of business and legal advice, the Commission voted to adopt the hearing officer’s decision. The superior court affirmed on appeal. The Supreme Court reversed, holding that the Commission failed to apply the proper standard for assessing the communications at issue. Remanded. View "Harrington v. Freedom of Info. Comm’n" on Justia Law

Pursuant to a plea agreement, Petitioner pleaded guilty to one count of possession of a controlled substance with intent to sell. After Petitioner was released from custody, federal authorities entered a final order of removal based on Petitioner’s felony conviction. Petitioner filed a habeas corpus petition claiming that his trial counsel’s assistance was deficient because counsel failed to advise him of the immigration consequences of his guilty plea, as required by Padilla v. Kentucky. The habeas court granted the petition and ordered that Petitioner’s conviction be vacated, holding that counsel was required to inform Petitioner that his plea of guilty to an aggravated felony made him subject to mandatory deportation. The State appealed, arguing that Padilla requires only that counsel advise a client of a heightened risk of deportation, not that federal law mandates deportation. The Supreme Court affirmed, holding that, because federal law called for deportation for Petitioner’s conviction, counsel was required to unequivocally convey to Petitioner that federal law mandated deportation as the consequence for pleading guilty. View "Budziszewski v. Comm’r of Corr." on Justia Law

Defendant was charged with several offenses after shooting Albert Weibel during an attempted robbery. Before trial, Defendant moved to preclude Weibel from making an in-court identification of Defendant, arguing that in-court identification procedures are unnecessarily suggestive. The trial court denied the motion pursuant to State v. Smith. During trial, Weibel identified Defendant as his assailant. The jury subsequently found Defendant guilty of conspiracy to commit robbery in the first degree and assault in the first degree. The Appellate Court affirmed. Defendant appealed, arguing that the Supreme Court should overrule the holding in Smith and hold that inherently suggestive in-court identifications are inadmissible even in the absence of a suggestive pretrial identification procedure. The Supreme Court affirmed, holding (1) first time in-court identifications must be prescreened for admissibility by the trial court; (2) Weibel’s in-court identification was a first time in-court identification and should have been prescreened, and the failure to follow the procedures outlined in this opinion potentially violated Defendant’s due process rights; but (3) any due process violation was harmless beyond a reasonable doubt. View "State v. Dickson" on Justia Law

After a jury trial, Defendant was convicted of murder. Defendant appealed, arguing that the trial court violated his right to present a defense by limiting his cross-examination of investigating police officers as to whether the murder investigation conformed to general police practices and/or standard police investigative procedures. The Appellate Court agreed with Defendant and reversed and remanded the case for a new trial. The Supreme Court reversed, holding that there was an absence of a sufficient offer of proof to such a line of inquiry, and therefore, the trial court did not improperly preclude Defendant’s inadequate investigation defense strategy. View "State v. Wright" on Justia Law