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Connecticut

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Membrino v. Membrino — Litigation Privilege Bars IIED Claim Arising from Probate Conservatorship Proceedings

Connecticut Appellate Court holds that the litigation privilege bars an IIED claim arising from an allegedly fraudulent probate conservatorship proceeding, ruling that downstream out-of-court conduct taken pursuant to conservator authority obtained in the proceeding cannot be carved out as independently actionable.

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Mack v. Commissioner — Appellate Court Denies Second Habeas Petition Raising Crawford Confrontation Clause and Sentence Review Claims

Connecticut Appellate Court affirms denial of a second habeas petition, holding that trial counsel’s failure to raise a Crawford Confrontation Clause objection at a 2008 murder trial was not deficient when the law was unsettled, and habeas counsel was not ineffective for failing to raise a sentence review claim the petitioner never communicated.

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