Connecticut Case Commentaries

State v. Kim: Supervisory Limits on “Consciousness of Guilt” Jury Instructions

Date: Jul 29, 2026

State v. Kim: Supervisory Limits on “Consciousness of Guilt” Jury Instructions (and a Call to Abolish Them) 1. Introduction State v. Kim (Conn. July 28, 2026) reached the Supreme Court of Connecticut...

State v. Kim (Conn. 2026): Narrowing and Rebalancing “Consciousness of Guilt” Jury Instructions

Date: Jul 29, 2026

State v. Kim: Connecticut Clarifies When (and How) Trial Courts May Give “Consciousness of Guilt” Instructions—Necessity, Neutrality, and No Prejudicial Labeling Court: Supreme Court of Connecticut...

Markatos v. Zoning Board of Appeals — Commentary

Date: Jul 22, 2026

“Material Change” Means a Significant Change in Character and “Intensification” Means a Meaningful Increase in Degree Under Special Permit Conditions (Not the Nonconforming-Use Test) Introduction In...

Exclusive State Forester Review: Municipal Assessors Lack Power to Terminate Erroneous Forest Land Classifications

Date: Jul 22, 2026

Exclusive State Forester Review: Municipal Assessors Lack Power to Terminate Erroneous Forest Land Classifications 1. Introduction In Campelli v. Mansfield (Supreme Court of Connecticut, officially...

Trial Courts Must Decide Timely Motions to Open Before Finalizing Adoption When the Motion Could Affect Best-Interest Determinations

Date: Jul 18, 2026

Trial Courts Must Decide Timely Motions to Open Before Finalizing Adoption When the Motion Could Affect Best-Interest Determinations Case: In re Jewelyette M. (SC 21227) — Supreme Court of...

State v. Mallozzi (Conn. 2026): Late-Disclosed Defense Experts Require Good Cause and a Meaningful Proffer

Date: Jul 13, 2026

State v. Mallozzi (Conn. 2026): Late-Disclosed Defense Experts Require Good Cause and a Meaningful Proffer Court: Supreme Court of Connecticut | Officially released: July 14, 2026 1. Introduction...

State v. Roman: § 54-84 (b) Requires a No-Adverse-Inference Instruction in the Final Charge; Suplicki’s Automatic Reversal Rule Overruled

Date: Jul 11, 2026

State v. Roman: § 54-84 (b) Requires a No-Adverse-Inference Instruction in the Final Charge; Suplicki’s Automatic Reversal Rule Overruled 1. Introduction State v. Roman is a Supreme Court of...

Dissenting Rule: § 54-84(b) Timing Is Not “Plain Error” When the No‑Adverse‑Inference Instruction Is Given Preliminarily

Date: Jul 11, 2026

Dissenting Rule: § 54-84(b) Timing Is Not “Plain Error” When the No‑Adverse‑Inference Instruction Is Given Preliminarily 1. Introduction State v. Roman (Dissent) is a Connecticut Supreme Court...

Liberal Permissive Intervention for Fair Rent Commissions to Protect Institutional Authority in Related Summary Process Actions

Date: Jul 2, 2026

Liberal Permissive Intervention for Fair Rent Commissions to Protect Institutional Authority in Related Summary Process Actions 1. Introduction In Kosel Equity, LLC v. MacGregor (Conn. June 30,...

State v. Ragin: Overproduced Cell-Phone Records—Retention/Use Is Challengeable Without a Second Warrant, but Suppression Is Not Automatic

Date: Jul 2, 2026

Overproduced Cell-Phone Records: Retention/Use Without a Second Warrant Is Constitutionally Challengeable, but Suppression Is Not Automatic I. Introduction In State v. Ragin (Conn. June 30, 2026),...

Hilton v. Commissioner of Correction: Lapointe Is an Exceptional Clear-Error Case, Not a New Expert-Credibility Standard Under Strickland

Date: Jul 2, 2026

Hilton v. Commissioner of Correction: Lapointe Is an Exceptional Clear-Error Case, Not a New Expert-Credibility Standard Under Strickland 1. Introduction In Hilton v. Commissioner of Correction...

Implied Presumption for In-State Placement and Separate “Good Cause” Findings Under § 46b-129 (j) (4)

Date: Jun 24, 2026

Implied Presumption for In-State Placement and Separate “Good Cause” Findings Under § 46b-129 (j) (4) Case: In re Dynastie D. (SC 21157) (Conn. June 17, 2026, officially released) Court: Supreme...

State v. Raeon A.: No Golding Review and No Plain Error for Daniel W. E. Delayed-Reporting Instruction Given Under Then-Governing Law

Date: Jun 24, 2026

State v. Raeon A.: No Golding Review and No Plain Error for Daniel W. E. Delayed-Reporting Instruction Given Under Then-Governing Law 1. Introduction In State v. Raeon A. (Conn. Sup. Ct., officially...

Daniels v. Commissioner of Revenue Services: Preponderance Standard and De Novo Review for Connecticut Estate-Tax Domicile Appeals

Date: Jun 14, 2026

Preponderance Standard and De Novo Review for Connecticut Estate-Tax Domicile Appeals Case: Daniels v. Commissioner of Revenue Services (SC 21150) Court: Supreme Court of Connecticut Officially...

Trial Courts May Stay Nonpayment Summary Process Actions Pending Fair Rent Commission Administrative Appeals

Date: Jun 8, 2026

Trial Courts May Stay Nonpayment Summary Process Actions Pending Fair Rent Commission Administrative Appeals 1. Introduction In TOV Realty, LLC v. Suarez (officially released June 9, 2026), the...

Lost-Note Foreclosures: Summary Judgment Requires Competent, Nonconclusory Secondary Evidence of Debt Ownership

Date: Jun 2, 2026

Lost-Note Foreclosures: Summary Judgment Requires Competent, Nonconclusory Secondary Evidence of Debt Ownership Case: Wilmington Savings Fund Society, FSB v. Schulz (SC 21065) Court: Supreme Court of...

State v. Rohena: Independent-Source Admission of In-Court Identifications After a Suppressed Out-of-Court Identification (Especially Where the Witness Is Familiar with the Defendant)

Date: Jun 2, 2026

State v. Rohena: Independent-Source Admission of In-Court Identifications After a Suppressed Out-of-Court Identification (Especially Where the Witness Is Familiar with the Defendant) Supreme Court of...

Misdesignation of Owner’s Capacity in a Notice to Quit Is a Circumstantial Defect Excused by § 52-123 Absent Prejudice

Date: May 27, 2026

Misdesignation of Owner’s Capacity in a Notice to Quit Is a Circumstantial Defect Excused by § 52-123 Absent Prejudice I. Introduction Freccia v. Freccia (Conn. May 26, 2026) is a summary process...

Strict Limits on § 4-175 Declaratory Jurisdiction: Pure Contract Interpretation of PURA Settlements Is Not “Applicability” of a Statute

Date: May 22, 2026

Strict Limits on § 4-175 Declaratory Jurisdiction: Pure Contract Interpretation of PURA Settlements Is Not “Applicability” of a Statute Case: Vistra Corp. v. Public Utilities Regulatory Authority...

Uncontested PURA RPS Determinations Are Not Appealable “Final Decisions,” but Declaratory-Judgment Review Remains Available via §§ 4-176/4-175 When the Dispute Turns on the Applicability of the RPS Statutes

Date: May 22, 2026

Uncontested PURA RPS Determinations Are Not Appealable “Final Decisions,” but Declaratory-Judgment Review Remains Available via §§ 4-176/4-175 When the Dispute Turns on the Applicability of the RPS...