Caruso v. City of Bridgeport

937 A.2d 1, 284 Conn. 793, 2007 Conn. LEXIS 517
CourtSupreme Court of Connecticut
DecidedNovember 5, 2007
DocketSC 18012
StatusPublished
Cited by6 cases

This text of 937 A.2d 1 (Caruso v. City of Bridgeport) is published on Counsel Stack Legal Research, covering Supreme Court of Connecticut primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Caruso v. City of Bridgeport, 937 A.2d 1, 284 Conn. 793, 2007 Conn. LEXIS 517 (Colo. 2007).

Opinion

Opinion

ROGERS, C. J.

The plaintiff, Christopher Caruso, brought this action pursuant to General Statutes § 9-329a (a),1 claiming, inter alia, that the defendant Santa Ayala, the Democratic registrar of voters for the city of [796]*796Bridgeport (city), had violated certain election statutes before, during and after the September 11, 2007 Democratic primary for the office of the mayor of the city.2 After an expedited hearing, the trial court rendered judgment for the defendants. The plaintiff then brought an appeal.3 At the same time, the plaintiff filed in this [797]*797court a motion to stay pursuant to Practice Book § 61-11,4 requesting postponement of the city’s general election scheduled for November 6, 2007, pending resolution of the appeal. We denied the motion and indicated that a full opinion explaining our decision would be released at a later date. This is that opinion. We conclude that the motion to stay should be denied because the automatic stay provision of § 61-11 did not apply to the city’s general election for mayor, this court has no authority to order postjudgment injunctive relief that was not requested in the underlying complaint and, even if this court had such authority, it has no authority to postpone a general election in an action pursuant to § 9-329a under any circumstances.

The record reveals the following undisputed facts and procedural history. The plaintiff was a candidate for the office of mayor in the city’s September 11, 2007 Democratic primary. The defendant William Finch, another Democratic candidate for the office of mayor, won the primary election by 270 votes. Fourteen days after the primary, on September 25, 2007, the plaintiff filed a complaint in the Superior Court alleging that, before, during and after the primary, Ayala had engaged in conduct that violated various election statutes. In [798]*798his original complaint, the plaintiff stated that he was bringing the action pursuant to General Statutes § 9-328, but he later clarified in his second amended complaint that he was bringing the action pursuant to § 9-329a.5 In each complaint, the plaintiff sought orders that (1) all of the voting machines used in the Democratic primary election be impounded beyond the automatic fourteen day impoundment period provided for in General Statutes § 9-310, (2) no Democratic nominee for mayor be recognized before the case was resolved, (3) the plaintiff be declared the winner of the Democratic primary for the office of mayor, (4) a new primary election be held and (5) the ballots cast in the primary election not be examined, unlocked or otherwise inspected except by order of the court.

The trial court ordered an expedited hearing on the matter to be held beginning on October 3, 2007. The trial court also issued an ex parte order that all of the voting machines used in the primary, as well as certain other materials related to the election, be impounded, pending further order by the court.

The expedited hearing concluded on October 15, 2007, and, on October 24, 2007, the trial court issued [799]*799its decision. The trial court determined that many of the alleged statutory violations by Ayala did not constitute “ ‘ruling[s]’ ” of an election official, as specified by § 9-329a, and, therefore, did not come within the scope of an action pursuant to § 9-329a. With respect to the actions by Ayala that colorably constituted rulings by an election official, the court concluded that the plaintiff had failed to prove: (1) that the rulings were improper; (2) that the results of the primary might have been different if the rulings had been different; or (3) what the outcome would have been if the rulings had been different. Accordingly, the trial court rendered judgment for the defendants and, pursuant to § 9-329a (b), certified his decision to the secretary of the state.

On October 26, 2007, the defendants filed a motion to vacate the trial court’s impoundment order so that the voting machines could be prepared for the city’s general election on November 6, 2007. The plaintiff objected to the motion and requested that the trial court certify the question of whether the impoundment order should be vacated to the Chief Justice of the Connecticut Supreme Court pursuant to General Statutes § 9-325. After a hearing, the trial court granted the defendants’ motion to vacate the impoundment order and denied the plaintiffs request to certify the question to the Chief Justice.

On October 30, 2007, the plaintiff filed a motion to postpone the general election “during the pendency of [his] appeal to the Supreme Court.”6 In the motion, he also requested that the question of whether the election should be postponed be certified to the Chief Justice pursuant to § 9-325. The trial court denied the motion.

On November 1, 2007, the plaintiff filed an appeal, citing General Statutes §§ 51-199 (b) (5) and 9-325 as the statutory bases for the Supreme Court’s appellate [800]*800jurisdiction over the matter. See footnote 3 of this opinion. In his preliminary statement of issues, the plaintiff raised numerous claims relating to the merits of the trial court’s judgment in favor of the defendants, the vacating of the impoundment order, the denial of the motion to postpone the election and the denials of the plaintiffs requests to certify the questions of whether the impoundment order should be vacated and the election should be postponed to the Chief Justice pursuant to § 9-325. The plaintiff also filed a motion to stay pursuant to Practice Book § 61-11 in which he requested that the city’s general election for mayor, scheduled for November 6, 2007, be postponed “pending the appeal.” After the plaintiff filed his appeal and motion to stay, the trial court certified to the Chief Justice the question of whether the trial court was required to grant the plaintiffs motion to postpone the city’s general election for mayor pending the plaintiffs appeal.7

Thereafter, the defendants filed a motion to dismiss the certified appeal; see footnote 8 of this opinion; and an opposition to the plaintiffs motion to stay. With respect to the motion to stay, the defendants argued that the motion went to the merits of the trial court’s judgment in favor of the defendants and required this court to make de novo factual findings on the basis of evidence produced at the hearing. On the same day that the defendants filed their motion to dismiss and opposition to the motion to stay, the secretary of the state filed, and this court granted, a motion to intervene in the case for the purpose of opposing the plaintiff’s motion to stay. In her memorandum in opposition to the motion to stay, the secretary of the state contended that, under the standard set forth in Griffin Hospital [801]*801v. Commission on Hospitals & Health Care, 196 Conn. 451, 456, 493 A.2d 229 (1985), the motion should be denied. Id. (in ruling on motion to stay order of administrative agency, trial court considers “[1] the likelihood that the appellant will prevail; [2] the irreparability of the injury to be suffered from immediate implementation of the . . . order [under review]; [3] the effect of a stay upon other parties to the proceeding; and [4] the public interest involved”).

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Related

Lazar v. Ganim
334 Conn. 73 (Supreme Court of Connecticut, 2019)
Ruiz v. Victory Properties, LLC
184 A.3d 1254 (Connecticut Appellate Court, 2018)
Caruso v. City of Bridgeport
937 A.2d 7 (Supreme Court of Connecticut, 2007)
Simmons-Cook v. City of Bridgeport
936 A.2d 601 (Supreme Court of Connecticut, 2007)

Cite This Page — Counsel Stack

Bluebook (online)
937 A.2d 1, 284 Conn. 793, 2007 Conn. LEXIS 517, Counsel Stack Legal Research, https://law.counselstack.com/opinion/caruso-v-city-of-bridgeport-conn-2007.