Justia Civil Rights Opinion Summaries

After a jury trial, Defendant was convicted of two counts of kidnapping in the second degree and one count of risk of injury to a child. The Supreme Court reversed the judgment of the trial court as to one of the two kidnapping counts and remanded for a new trial on that charge, holding (1) Defendant was entitled to a jury instruction in accordance with State v. Salamon, which bars a jury from finding a defendant guilty of kidnapping if it finds that the restraint used in connection therewith was merely incidental to the restraint used in the commission of another offense, and (2) the trial court's failure to give such an instruction was not harmless beyond a reasonable doubt. The Supreme Court affirmed the trial court's judgment in all other respects.

Letitia Kilby filed a complaint with the Commission on Human Rights and Opportunities, claiming unlawful housing discrimination by Defendants, the town housing authority and a property management company. The Commission found reasonable cause to believe that unlawful discrimination occurred. The trial court then granted Defendants' request to file a civil action in the trial court. Kilby moved to intervene, claiming both intervention as of right and permissive intervention. The trial court denied the motion. The appellate court reversed, concluding that although the statute at issue, Conn. Gen. Stat. 46a-83(d)(2), did not expressly grant Kilby a right of intervention, it impliedly granted Kilby a right of intervention. The Supreme Court granted Defendants' petition for certification to appeal, but while the case was pending, the legislature enacted Conn. Pub. Acts 11-237, which amended the text of section 46a-83 to allow a complainant to intervene as of right in a housing discrimination action brought by the commission on behalf of the complainant. The Court dismissed the appeal, concluding that the significance of Defendants' appeal was substantially undermined by Conn. Pub. Acts 11-237, and, thus, certification was improvidently granted.

After a jury trial, defendant Oles Baptiste was convicted of assault of a peace officer and interfering with an officer. Defendant appealed, claiming that the trial court's jury instructions on the charges deprived him of his right to a fair trial and to present a defense. The appellate court affirmed, concluding that Defendant waived any constitutional or plain error claim by not raising an objection in the lower court proceedings. On appeal, Defendant claimed that the appellate court erred in concluding that he waived his claim of instructional error under State v. Kitchens, asserting that he did not have a meaningful opportunity for review of the jury instructions because the trial court held only a brief charging conference and Defendant did not receive a written copy of the instructions. The Supreme Court reversed the judgment of the appellate court, holding that because Defendant did not have a meaningful opportunity to review the charges, Defendant's claim was not implicitly waived under Kitchens. Remanded.

After a police officer received frantic telephone calls by a concerned parent about his missing teenage son and the parent suggested that his son might be at the home of defendant Gary Ryder, the officer conducted a warrantless search of Ryder's home. During the search, the officer found a large reptile in Ryder's tub. Ryder was charged with risk of injury to a child and illegal possession of a reptile. The State entered a nolle prosequi with regard to the first charge, and Ryder entered a plea of nolo contendere to the possession of a reptile charge, later paying a fine. Ryder appealed from the trial court's denial of his motions to suppress and to dismiss the charges. Ultimately, the appellate court affirmed, concluding that the emergency exception to the warrant requirement justified the officer's entry into Ryder's home. On appeal, the Supreme Court reversed the judgment of the appellate court, holding that the emergency exception to the warrant requirement did not justify the warrantless search of Ryder's curtilage and the subsequent warrantless search of Ryder's home. Remanded.

Defendant Calvin Long was committed to the jurisdiction of the psychiatric security review board following a finding of not guilty by reason of mental disease of assault in the second degree. The state later petitioned to continue the defendant's commitment under Conn. Gen. Stat. 17a-593(c), which the defendant challenged on equal protection grounds. The Supreme Court held that the legislature had a legitimate basis for providing review procedures for the continued commitment of insanity acquittees different from those afforded to civilly committed inmates. Following remand, the trial court granted the state's petition. The defendant appealed, claiming that the trial court improperly construed the Supreme Court's decision in the previous appeal to preclude his current equal protection challenge and that a higher level of scrutiny of the statutory scheme should apply to this claim than the Court had applied to his claim in the previous appeal. The Supreme Court affirmed the judgment of the trial court, holding that its decision in the previous appeal precluded the defendant's present claims.

In 2000, the manager of the Goodspeed Airport cut down trees and woody vegetation on property owned by a land trust. A total of six actions were filed as a result of the clear-cutting. In addition to instituting two of three consolidated actions, the airport brought two federal actions, and the district court found in favor of the land trust in both actions. In state court three other actions were consolidated. The trial court concluded that (1) the airport parties' claims for substantive and procedural due process were barred by the doctrine of res judicata, and (2) the airport parties' claims claims for first amendment retaliation and abuse of process were barred by the doctrine of collateral estoppel. The Supreme Court affirmed, holding that either the issues were actually litigated in the federal actions and thus are barred by collateral estoppel, or the claims could have been raised in the federal actions and thus are barred by res judicata.

Plaintiff sued defendants alleging violations of 42 U.S.C. 1983 and General Statutes 7-465 when defendants terminated plaintiff from his employment as a senior field engineer in defendants' information technology department after it had determined that he was responsible for disruptions in its computer network. At issue was whether the trial court abused its discretion in awarding defendants a portion of defendants' attorney's fees that it incurred in defending against plaintiff's action. The court held that the trial court acted well within its discretion in awarding attorney's fees where plaintiff continued to litigate his claims against defendants after it became clear that those claims were groundless.