SC20947 - State v. Mieles (“This appeal requires us to clarify the standards that apply to a trial court’s determination to impose a postsentencing standing criminal protective order pursuant to General Statutes § 53a-40e (a). The defendant, Juan Mieles, appeals from the judgment of the Appellate Court, which affirmed the trial court’s imposition of a standing criminal protective order against him more than nine years after he was sentenced. The defendant claims that the Appellate Court (1) incorrectly concluded that he did not challenge the imposition of the standing criminal protective order on the basis that the trial court had failed to abide by the standard applicable to such orders set forth in § 53a-40e (a), and (2) improperly issued the protective order in the absence of a finding of changed circumstances. We agree with the defendant that he adequately briefed his claim before the Appellate Court that the trial court had employed an incorrect legal standard in issuing the postsentencing criminal protective order. Although we disagree with his characterization that § 53a-40e (a) requires a finding of changed circumstances, we conclude that, when a standing criminal protective order is issued postsentencing, in addition to its express requirements, § 53a-40e also requires the issuing court to find that additional evidence, which had not been presented to the sentencing court, demonstrates that the issuance of the protective order would ‘best serve the interest of the victim and the public . . . .’ General Statutes § 53a-40e (a). Accordingly, we reverse the judgment of the Appellate Court and remand the case to that court with direction to vacate the trial court’s order.”)

• Posted in:
• Criminal Law & Procedure,
• Recent Opinions

AC46470 - Christensen v. Christensen ("In this postjudgment marital dissolution action, the self-represented defendant, Madelyn Christensen, appeals from the judgment of the trial court resolving several motions filed by the defendant and by the plaintiff, Eugene Christensen. Specifically, the defendant claims on appeal that the court erred in granting the plaintiff's motion for contempt and denying the defendant's motion for modification on the basis that it (1) improperly determined that she had engaged in parental alienation, (2) did not give her the opportunity to cross-examine the plaintiff, and (3) abused its discretion in awarding the plaintiff attorney's fees. We dismiss in part the defendant's appeal and otherwise affirm the judgment of the trial court.")

• Posted in:
• Family Law,
• Recent Opinions

AC46253 - State v. Overstreet (“On appeal, the defendant claims that (1) the trial court improperly denied his motion to suppress evidence seized from his vehicle, (2) § 29-38 violates his right to bear arms under the second amendment to the United States constitution, (3) § 29-38 is unconstitutionally vague as applied to him, in violation of his due process rights, and (4) § 29-38 is unconstitutionally overinclusive in violation of his due process rights. We affirm the judgment of the trial court.”)

AC46807 - State v. William G. (“On appeal, the defendant claims that the court improperly (1) instructed the jury not to consider that the victim delayed reporting the sexual assault in evaluating her credibility, and (2) denied his request to instruct the jury that, in evaluating evidence of uncharged misconduct offered by the state to prove the defendant’s propensity to commit the charged crimes, it must first determine whether the state proved that the defendant had engaged in such conduct by a preponderance of the evidence. We agree that the court’s delayed reporting instruction was improper and harmful, and, accordingly, we reverse the judgment of the court.”)

AC47242 - State v. Sharpley (“On appeal, the defendant claims that the court erred in denying his motion to dismiss because the state’s delay in the execution of the arrest warrant violated his due process rights under the Connecticut constitution and the United States constitution. We disagree and, accordingly, affirm the judgment of the trial court.”)

• Posted in:
• Criminal Law & Procedure,
• Recent Opinions

AC46682 - Vazquez v. Commissioner of Correction (Risk reduction credits; parole eligibility date; “On appeal, the petitioner claims that the court (1) abused its discretion in denying his petition for certification to appeal and (2) improperly dismissed the habeas petition pursuant to Practice Book § 23-29. We conclude that the court did not abuse its discretion in denying the petition for certification to appeal and, therefore, dismiss the appeal.”)

• Posted in:
• Habeas Corpus Law,
• Recent Opinions

Monday, April 28th

• Rockville Law Library is closed.
• Stamford Law Library opens at 10:30 a.m.
• Torrington Law Library opens at 11:30 a.m.
• Putnam Law Library is open from 9:30 a.m. through 3:30 p.m.

Tuesday, April 29th

• Putnam Law Library is closed.
• Torrington Law Library is closed.
• Rockville Law Library closes at 4:00 p.m.
• New London Law Library opens at 10:45 a.m.
• Danbury Law Library is open from 9:30 a.m. through 3:30 p.m.

Wednesday, April 30th

• Waterbury Law Library is closed.
• Torrington Law Library is closed.
• Rockville Law Library is closed.
• Putnam Law Library is open from 9:30 a.m. through 3:30 p.m.

Thursday, May 1st

• Rockville Law Library closes at 4:00 p.m.
• Putnam Law Library is open from 9:30 a.m. through 3:30 p.m.

Friday, May 2nd

• Rockville Law Library closes at 4:00 p.m.
• Torrington Law Library closes at 4:00 p.m.
• Danbury Law Library is closed.

• Posted in:
• Library Notices

AC47145 - U.S. Bank National Assn. v. Nehring ("In this protracted foreclosure matter, the self-represented defendant Alexander T. Nehring appeals from the judgment of the trial court denying his motion to open and to vacate the court's judgment of strict foreclosure rendered in favor of the plaintiff, U.S. Bank National Association. The dispositive issue in this appeal is whether the defendant filed 'at least two prior motions to open or other similar motion' pursuant to Practice Book § 61-11(g), such that an automatic appellate stay did not apply to toll the running of the law days. We conclude that no automatic stay applied, and, thus, the law days have passed, divesting the defendant of his interest in the property, and title to the property has vested in the plaintiff. Accordingly, this court cannot provide the defendant any practical relief, and we, therefore, dismiss this appeal as moot.")

• Posted in:
• Foreclosure Law,
• Recent Opinions

The Connecticut Law Journal, Volume LXXXVI, No. 43, for April 22, 2025 is now available.

• Table of Contents
• Volume 351: Connecticut Reports (Pages 745 - 765)
• Volume 351: Orders (Pages 923 - 924)
• Volume 351: Cumulative Table of Cases Connecticut Reports
• Volume 232: Connecticut Appellate Reports (Pages 104 - 220)
• Volume 232: Cumulative Table of Cases Connecticut Appellate Reports
• Connecticut Practice Book Amendments

• Posted in:
• Connecticut Law Journal,
• Recent Opinions

AC47618 - In re Elena M. ("The respondent father, Christopher W., appeals from the judgment of the trial court rendered in favor of the petitioner, the Commissioner of Children and Families, terminating his parental rights as to his minor child, Elena M., on the ground that he failed to achieve a sufficient degree of rehabilitation pursuant to General Statutes § 17a-112 (j) (3) (B) (i) and (E). On appeal, the respondent claims that the court (1) violated his constitutional right to procedural due process by denying his oral motion for a continuance during the trial on the operative petition to terminate his parental rights, or (2) in the alternative, the court abused its discretion in denying the motion. We conclude that, in denying the motion for a continuance, the court did not (1) violate the respondent’s right to due process or (2) abuse its discretion. Accordingly, we affirm the judgment of the trial court.")

• Posted in:
• Juvenile Law,
• Recent Opinions

Monday, April 21st

• Putnam Law Library is open from 9:30 a.m. through 3:30 p.m.
• Danbury Law Library opens at 11:00 a.m.
• Torrington Law Library opens at 11:30 a.m.
• Rockville Law Library is closed.

Tuesday, April 22nd

• Rockville Law Library closes at 3:30 p.m.
• Putnam Law Library is closed.

Wednesday, April 23rd

• Rockville Law Library is closed.
• New Britain Law Library closes at 12:00 p.m.
• Putnam Law Library is open from 9:30 a.m. through 3:30 p.m.

Thursday, April 24th

• Danbury Law Library closes at 4:30 p.m.
• Putnam Law Library is open from 9:30 a.m. through 3:30 p.m.
• Rockville Law Library closes at 4:00 p.m.

Friday, April 25th

• Danbury Law Library opens at 10:30 a.m.
• Rockville Law Library closes at 3:30 p.m.
• Putnam Law Library is closed.

• Posted in:
• Library Notices

AC47229 - K. S. v. C. S. ("The plaintiff, K. S., appeals from the judgment of the trial court dissolving her marriage to the defendant, C. S., which included a finding of contempt against the plaintiff. On appeal, the plaintiff claims that the court improperly (1) entered an order in the judgment of dissolution prohibiting contact between the parties’ minor child and the plaintiff’s boyfriend, A, (2) awarded the defendant final decision-making authority with respect to the child’s medical and educational issues, (3) granted the defendant’s motion for contempt alleging violations of the court’s interim order prohibiting contact between the child and A, (4) ordered the plaintiff to pay attorney’s fees in connection with the defendant’s motions for contempt, (5) entered orders regarding child support, specifically challenging its factual findings as to the parties’ incomes, and (6) entered orders regarding the division of marital property, specifically challenging its factual finding regarding the equity in the marital home.

"We disagree with the plaintiff’s first and second claims. With respect to the third and fourth claims, we conclude that, although the court did not abuse its discretion in finding the plaintiff in contempt of its no contact interim order, its awards of attorney’s fees constituted an abuse of its discretion. Accordingly, we remand the case for reconsideration of the attorney’s fees awards. Finally, we agree with the plaintiff’s fifth and sixth claims and conclude that the court made clearly erroneous factual findings underlying its child support and division of marital property orders. Because these orders are not severable from the other financial orders, we reverse the judgment of the trial court with respect to the financial orders and remand this case for a new trial on all financial issues.")

• Posted in:
• Family Law,
• Recent Opinions

AC47394 - Zhuleku v. Naugatuck Valley Radiology Associates ("In this medical malpractice action, the plaintiffs, Nexhmije Zhuleku (Zhuleku) and her husband, Fuat Zhuleku (husband), appeal from the judgment of the trial court rendered after the court directed the verdict in favor of the defendant Lauren Perugini (substitute defendant), in her capacity as executrix of the estate of the defendant Josephine Perugini (Perugini), and, after a jury trial, in favor of the defendants Naugatuck Valley Radiology Associates (NVRA) and Gregory D. Gersten. The plaintiffs claim that the court improperly (1) sustained the defendants' objection to their amended revised complaint and (2) instructed the jury after denying their requests to charge. We disagree and, accordingly, affirm the judgment of the court.")

• Posted in:
• Medical Malpractice Law,
• Recent Opinions

AC46428 - State v. Colon (“The defendant, Luis E. Colon, appeals from the judgments of conviction, rendered following a jury trial, of possession of a controlled substance in violation of General Statutes § 21a-279 (a) (1) (count one) and operation of a motor vehicle while having an elevated blood alcohol content in violation of General Statutes § 14-227a (a) (2) (count two). The defendant claims that (1) the trial court committed plain error in failing, sua sponte, to sever the two offenses joined in the same information and (2) the evidence was insufficient to support his conviction with respect to count two. We disagree and, accordingly, affirm the judgments of the court.”)

• Posted in:
• Criminal Law & Procedure,
• Recent Opinions

AC47311 - Aspen Properties Group, LLC v. Roberts-Joachim ("The defendant Cathleen Roberts-Joachim, now known as Cathleen Roberts, appeals from the judgment of foreclosure by sale rendered following a court trial in favor of the substitute plaintiff, Wilmington Savings Fund Society, FSB, not in its individual capacity but solely as Owner Trustee of the Aspen G Trust, a Delaware Statutory Trust. In this appeal, the defendant's principal claim is that the trial court improperly failed to find that one of the substitute plaintiff's predecessors, PNC Bank, N.A. (PNC), abandoned the mortgage that the substitute plaintiff sought to foreclose. We affirm the judgment of the trial court and remand the case for the purpose of setting a new sale date.")

• Posted in:
• Foreclosure Law,
• Recent Opinions

SC20983 - State v. Wade (“In this certified appeal, the defendant, Jaquan Wade, appeals from the Appellate Court’s judgment affirming the trial court’s revocation of his probation and imposition of a thirteen year term of incarceration. The defendant claims that the Appellate Court incorrectly concluded that, at his probation revocation hearing, he had abandoned his argument that the trial court should engage in a due process balancing under State v. Crespo, 190 Conn. App. 639, 646–48, 211 A.3d 1027 (2019), before admitting into evidence a witness’ out-of-court identification when that witness was not present and available for cross-examination. We agree and reverse the Appellate Court’s judgment.”)

• Posted in:
• Criminal Law & Procedure,
• Recent Opinions

The Connecticut Law Journal, Volume LXXXVI, No. 42, for April 15, 2025 is now available.

• Table of Contents
• Volume 351: Connecticut Reports (Pages 722 - 745)
• Volume 351: Orders (Pages 919 - 922)
• Volume 351: Cumulative Table of Cases Connecticut Reports
• Volume 232: Connecticut Appellate Reports (Pages 1 - 104)
• Volume 232: Cumulative Table of Cases Connecticut Appellate Reports
• Miscellaneous Notices
• Connecticut Practice Book Amendments

• Posted in:
• Connecticut Law Journal,
• Recent Opinions

AC47980 - In re Christopher C. ("The respondent father, Christopher C., appeals from the judgment of the trial court rendered in favor of the petitioner, the Commissioner of Children and Families, terminating his parental rights with respect to his minor child, Christopher C., and denying the respondent's motions for transfer of guardianship and for out-of-state placement. On appeal, the respondent claims that the court abused its discretion in denying the respondent's oral motion for disqualification. We affirm the judgment of the trial court.")

• Posted in:
• Juvenile Law,
• Recent Opinions

AC46927 - Torrington v. Council 4, AFSCME, AFL-CIO, Local 442 ("The defendants, Council 4, AFSCME, AFL-CIO, Local 442 (union), and Gerald Peters, appeal from the judgment of the trial court vacating an arbitration award that ordered the plaintiff, the city of Torrington (city), to, inter alia, reinstate Peters as a sergeant in the Torrington Police Department (department).On appeal, the defendants argue that the trial court (1) improperly concluded that the arbitration panel manifestly disregarded the law, (2) improperly concluded that the award violated public policy, and (3) abused its discretion by remanding the case to a new arbitration panel. We agree with the defendants' first two claims. We therefore reverse the judgment of the court and remand the case for further proceedings consistent with this opinion. In light of our disposition of the defendants' first two claims, we do not reach the merits of their third claim.")

• Posted in:
• Employment Law,
• Recent Opinions

AC47221 - Fezollari v. Jauzovic (“On appeal, the defendant claims that, at the hearing in damages, the court (1) improperly denied her the opportunity to present evidence to mitigate damages as provided for in Practice Book §§ 17- 34 (a) and 17-40 and (2) used an incorrect measure of damages in calculating the damages award. We agree with the defendant as to both claims and, accordingly, reverse in part the judgment of the court as to the award of damages and remand the case for a new hearing in damages.”)

• Posted in:
• Contract Law,
• Recent Opinions

Monday, April 14th

• Rockville Law Library is closed.
• Putnam Law Library is closed.
• Middletown Law Library is closed.
• Danbury Law Library closes at 3:00 p.m.

Tuesday, April 15th

• Torrington Law Library is closed from 11:00 a.m. through 1:00 p.m.
• Danbury Law Library closes at 3:45 p.m.
• Putnam Law Library is open from 9:30 a.m. through 3:30 p.m.
• Rockville Law Library closes at 4:00 p.m.

Wednesday, April 16th

• Putnam Law Library is closed.
• Rockville Law Library is closed.

Thursday, April 17th

• Danbury Law Library closes at 3:30 p.m.
• Rockville Law Library closes at 2:00 p.m.
• Putnam Law Library is open from 9:30 a.m. through 3:30 p.m.

Friday, April 18th

• All Connecticut Judicial Branch Law Libraries are closed for the holiday.

• Posted in:
• Library Notices

AC47261 - Smith v. H. Pearce Real Estate Co. (“In this appeal from the judgments in two consolidated actions arising from an asset purchase agreement, the plaintiffs in the first action, DeForest W. Smith and DeForest Industries, Inc. (DII), challenge the judgments of the trial court, rendered after a court trial. On appeal, the plaintiffs claim that the court improperly (1) found that the defendant H. Pearce Real Estate Company, Inc. (Pearce) was entitled to a setoff for the overpayment of a commission that it previously had paid to Smith, (2) concluded that Smith was personally liable to Pearce for the setoff, and (3) rejected their claim that certain lease renewals were excluded from its sale of assets to Pearce. We affirm the judgments of the trial court.”)

• Posted in:
• Contract Law,
• Recent Opinions