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Richardson v. Semple

2025-12-09

Summary

Holding. The appeal was dismissed for lack of subject matter jurisdiction because the ACLU failed to make a colorable claim of intervention as a matter of right, and therefore the trial court's denial of the intervention motion was not a final judgment.

The American Civil Liberties Union Foundation of Connecticut sought to intervene in a civil rights case for the limited purpose of arguing against the sealing of a video recording depicting the death of the plaintiffs' decedent. The trial court denied the intervention motion, and the ACLU appealed. The appellate court examined whether the ACLU could make a colorable claim to intervention as a matter of right, which is a prerequisite for the denial of an intervention motion to constitute a final, appealable judgment.

The court concluded that the ACLU failed to establish a direct and substantial interest in the sealing issue that distinguishes it from any member of the general public. The ACLU's argument that its interest became personal simply because it had requested and been denied access to the video was rejected as circular reasoning. The court noted that under Connecticut's rules of practice governing court filings, all members of the public already possess the right to access court documents and the opportunity to be heard at sealing hearings, making the ACLU's claimed interest indistinguishable from that of the general public.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

  • Whether an appeal from the denial of a motion to intervene is a final judgment requiring a colorable claim of intervention as of right
  • Whether the ACLU possessed a direct and substantial interest in the sealing of the video recording distinct from the general public's interest
  • Whether seeking and being denied access to a document creates a sufficient personal interest to meet intervention requirements

Procedural posture

The ACLU appealed the trial court's denial of its motion to intervene in an underlying civil rights action.

Authorities cited

Opinion

majority opinion

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Richardson v. Semple

LYNNETTE RICHARDSON, ADMINISTRATRIX

(ESTATE OF J’ALLEN JONES), ET AL. v.

SCOTT SEMPLE ET AL.

(AC 48427)

Cradle, C. J., and Alvord and Seeley, Js.

Syllabus

The proposed intervenor, A Co., appealed from the trial court’s judgment

denying its motion to intervene in the underlying action for the limited

purpose of litigating the issue of whether a certain video recording filed as

an exhibit to the defendants’ memorandum of law in support of their motion

for summary judgment should be sealed pursuant to our rule of practice

(§ 11-20A) governing the disclosure of court filings to the public. A Co.

claimed that it had a specific, personal and legal interest in the issue of

whether the video recording may be lawfully sealed. Held:

The trial court’s denial of A Co.’s motion to intervene was not a final judgment

for purposes of this appeal, as A Co. failed to make a colorable claim of

intervention as of right; accordingly, this court dismissed the appeal.

Argued October 6—officially released December 9, 2025

Procedural History

Action to recover damages for, inter alia, alleged violations of the civil rights of the plaintiffs’ decedent, and

for other relief, brought to the Superior Court in the

judicial district of Hartford, where the court, Noble, J.,

granted the motion to dismiss all claims as to the named

defendant et al.; thereafter, the court, Baio, J., denied

the motion to intervene filed by the American Civil

Liberties Union Foundation of Connecticut, and the

American Civil Liberties Union Foundation of Connecticut appealed to this court. Appeal dismissed.

Jaclyn Blickley, with whom were Dan Barrett and,

on the brief, Elana Bildner, for the appellant (proposed

intervenor).

Terrence M. O’Neill, assistant attorney general, with

whom were James Belforti, assistant attorney general,

and, on the brief, William Tong, attorney general, for

the appellees (defendant Anthony Kacpryzski et al.).

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Richardson v. Semple

Opinion

CRADLE, C. J. The American Civil Liberties Union

Foundation of Connecticut (ACLU) appeals from the

judgment of the trial court denying its motion to intervene in this action for the limited purpose of litigating

the issue of whether a certain video recording filed as

an exhibit to a memorandum of law in support of a

motion for summary judgment filed by the defendants,

various employees of the Department of Correction

(DOC),1 should be sealed pursuant to Practice Book

§ 11-20A.2 We conclude that the ACLU does not have a

colorable claim of intervention as of right and, therefore, is not appealing from a final judgment. Accordingly, we dismiss the appeal for lack of subject matter

jurisdiction.

The following procedural history is relevant to this

appeal. In August, 2018, the plaintiffs, Lynnette Richardson, the administratrix of the estate of J’Allen Jones

(decedent), and Jessica Jones, the mother of the decedent, brought this action pursuant to 42 U.S.C § 1983,

1

This action initially was brought against Scott Semple, the former Commissioner of Correction, as well as Anthony Corcella, Warden of Garner

Correctional Institution, and various correctional officers and medical unit

employees of Garner Correctional Institution. Dr. Susannah Tung, a psychiatrist, and Warden Denise Dilworth later were cited in as party defendants.

On March 18, 2021, the court, Noble, J., dismissed the claims against Semple

and Dilworth. The plaintiffs later withdrew their action as to Corcella, Tung

and a correctional officer identified only as ‘‘Ryan.’’

2

Practice Book § 11-20A provides in relevant part that, ‘‘(a) [e]xcept as

otherwise provided by law, there shall be a presumption that documents

filed with the court shall be available to the public,’’ that ‘‘(b) . . . the

judicial authority shall not order that any files, affidavits, documents, or

other materials on file with the court or filed in connection with a court

proceeding be sealed or their disclosure limited,’’ and that ‘‘(c) . . . [a]n

agreement of the parties to seal or limit the disclosure of documents on

file with the court or filed in connection with a court proceeding shall not

constitute a sufficient basis for the issuance of such an order. . . .’’ The

rule further provides that a motion to seal ‘‘shall be calendared so that

notice to the public is given of the time and place of the hearing on the

motion and to afford the public an opportunity to be heard on the motion

under consideration.’’ Practice Book § 11-20A (e).

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Richardson v. Semple

alleging in the operative complaint that the decedent’s

death, which occurred while in the custody of the DOC,

was caused by the excessive force to which he was

subjected by, and the deliberate indifference of, certain

correctional officers and nurses. On October 21, 2019,

the parties filed a joint motion for a protective order

with regard to the use of any DOC video recordings

during the litigation, which they averred was necessary

for the preservation of safety and security. In the

motion, the parties requested an order limiting disclosure of such videos to counsel of record for the parties,

as well as their staff, experts and investigators, the

court, court reporters, and witnesses at deposition or

trial. They also requested that the order provide that,

before submitting to the court any video recordings

subject to the protective order, the parties must jointly

request that they be filed under seal. On November 13,

2019, the court, Noble, J., granted the motion for a

protective order.

On March 5, 2024, the defendants filed a motion for

summary judgment, along with a supporting memorandum, to which they attached as an exhibit a video

recording of the events culminating in the decedent’s

death. The defendants did not request that the video

recording be filed under seal. On September 27, 2024,

the ACLU requested a copy of the video recording, but

the court, Morgan, J., denied the request on the ground

that it was subject to the protective order.

On October 4, 2024, the plaintiffs filed a motion seeking ‘‘an order declaring that the video showing the death

of [the decedent] is now accessible to the public and

press because the defendants submitted that video as

[an exhibit] in [support of] their motion for summary

judgment.’’ It does not appear that the court acted on

the plaintiffs’ motion. The plaintiffs later filed another

motion seeking the same relief, but that motion also

was not adjudicated.

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Richardson v. Semple

On October 7, 2024, the ACLU filed with this court

a petition for expedited review of the trial court’s denial

of its request for a copy of the video recording. This

court granted the petition for review, in part, and

vacated the trial court’s denial of the ACLU’s request

for a copy of the video recording and remanded the

matter to the trial court with direction to promptly

conduct a properly noticed public hearing in compliance with Practice Book § 11-20A on the issue of

whether the video recording should be sealed or its

disclosure limited in whole or in part. This court further

ordered that the video recording remain inaccessible

to the public pending the trial court’s resolution of the

proceeding on the sealing question.

On October 31, 2024, the ACLU filed a motion to

intervene for the limited purpose of contesting any limitation on the disclosure of the video recording in order

to advocate for ‘‘its—and the public’s—right of access

to the video.’’ The ACLU asserted in its motion that it

met the standards for both permissive and as of right

intervention. The ACLU argued, inter alia, that it ‘‘has

a direct and substantial interest in being added as a

party for the limited purpose of litigating public access

to [the video recording], which interest would be extinguished by an unfavorable ruling.’’ It argued that,

‘‘absent [its] participation, there very well may be no

advocate for public access to [the video recording].’’

The court indicated that it would consider the ACLU’s

motion to intervene, if necessary, after the Practice

Book § 11-20A sealing hearing.

On December 20, 2024, the court commenced the

Practice Book § 11-20A sealing hearing. Counsel for

the defendants argued in support of sealing the video

recording and counsel for the plaintiffs opposed sealing

the recording. Counsel for the ACLU asked the court

to grant its motion to intervene, stating that he sought

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Richardson v. Semple

the right to present evidence and cross-examine witnesses. The court reiterated that it would not rule on

the motion to intervene at that time. At the hearing,

issues regarding certain motions to quash subpoenas

were raised by the parties, making it clear that the

hearing could not conclude on that date. Counsel for

the ACLU therefore asked to be heard when the court

reconvened on the next hearing date. At the hearing,

three other members of the public were heard in opposition to the sealing of the video recording at issue.

On January 13, 2025, the court, Baio, J., denied the

ACLU’s motion to intervene, finding that the ACLU

failed to meet the legal requirements necessary for intervention and stating further that the ACLU already has

the opportunity to be heard by way of the sealing proceeding being held before it pursuant to Practice Book

§ 11-20A.3 The ACLU thereafter filed this appeal challenging the court’s denial of its motion to intervene.4

‘‘Unless a specific right to appeal otherwise has been

provided by statute, we must always determine the

3

The ACLU filed a motion for articulation of the court’s denial of its

motion to intervene, which the court denied.

4

While this appeal was pending, the sealing hearing resumed on August

22, 2025. At that hearing, counsel for the ACLU presented oral argument in

opposition to sealing the video recording. Attorney Alexander Taubes also

presented oral argument, on behalf of the CT Examiner, LLC, in opposition

to sealing the video recording. In addition, the court heard from several

other members of the public, including the plaintiffs.

On October 16, 2025, the court issued a memorandum of decision wherein

it determined that ‘‘the majority of the [video] recording cannot be sealed.’’

The court ordered the defendants to prepare a revised video recording with

specific limited redactions, furnish a copy of that revised video recording

to counsel for the plaintiffs for review and, provided there are no objections,

to file it with the court.

The ACLU subsequently sought leave to brief the issue of whether the

trial court’s decision rendered this appeal moot. Because we dismiss this

appeal for lack of a final judgment, we need not address the additional

jurisdictional query of what practical relief, if any, may be afforded to the

ACLU now that the court has ordered that a majority of the video recording

will not be sealed.

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Richardson v. Semple

threshold question of whether the appeal is taken from

a final judgment before considering the merits of the

claim. . . . The lack of a final judgment implicates the

subject matter jurisdiction of an appellate court to hear

an appeal. A determination regarding . . . subject matter jurisdiction is a question of law [over which we

exercise plenary review]. . . . Specifically, with regard

to motions to intervene, an unsuccessful applicant for

intervention in the trial court does not have a final

judgment from which to appeal unless [it] can make a

colorable claim to intervention as a matter of right. If

[it] does make such a colorable claim, on appeal the

court has jurisdiction to adjudicate both [its] claim to

intervention as a matter of right and to permissive intervention. . . . When prospective intervenors have not

made a colorable claim to intervene as a matter of right,

there is no right to interlocutory review of the order

denying their motion to intervene.’’ (Citations omitted;

internal quotation marks omitted.). In re Santiago G.,

325 Conn. 221, 228, 157 A.3d 60 (2017).

There is a ‘‘two part framework by which we consider

interlocutory appeals from a trial court’s decision to

deny a motion to intervene. The first part of the inquiry

focuses on whether the court’s judgment as to the

motion to intervene was a final judgment for purposes

of appeal. The right of appeal is purely statutory. It is

accorded only if the conditions fixed by statute and the

rules of court for taking and prosecuting the appeal are

met. . . . The statutory right to appeal is limited to

appeals by aggrieved parties from final judgments. . . .

Because our jurisdiction over appeals, both criminal

and civil, is prescribed by statute, we must always determine the threshold question of whether the appeal is

taken from a final judgment before considering the merits of the claim. . . . An otherwise interlocutory order

is appealable in two circumstances: (1) [when] the order

or action terminates a separate and distinct proceeding,

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Richardson v. Semple

or (2) [when] the order or action so concludes the rights

of the parties that further proceedings cannot affect

them. . . . Unless an order can satisfy one of these

two prongs, the lack of a final judgment is a jurisdictional defect that [necessitates] . . . dismissal of the

appeal. . . . For purposes of the appeal from a court’s

interlocutory ruling on a motion to intervene, only the

second prong of the . . . test is implicated.’’ (Citations

omitted; footnote omitted; internal quotation marks

omitted.) Id., 228–30.

‘‘[A]n unsuccessful applicant for intervention in the

trial court does not have a final judgment from which

to appeal unless [it] can make a colorable claim to

intervention as a matter of right. If [it] does make such

a colorable claim, on appeal the court has jurisdiction

to adjudicate both [its] claim to intervention as a matter

of right and to permissive intervention. . . . Accordingly, the dispositive inquiry into whether the denial of

a motion to intervene is an appealable, final judgment

is whether the intervenor can make a colorable claim

to intervention as a matter of right.’’ (Internal quotation

marks omitted.) Id., 230–31.

‘‘A colorable claim is one that is superficially well

founded but that may ultimately be deemed invalid

. . . . For a claim to be colorable, the [proposed intervenor] need not convince the trial court that [it] necessarily will prevail; [it] must demonstrate simply that [it]

might prevail. . . . In order for a proposed intervenor

to establish that it is entitled to intervene as a matter

of right, the proposed intervenor must satisfy a well

established four element conjunctive test: [t]he motion

to intervene must be timely, the movant must have a

direct and substantial interest in the subject matter of

the litigation, the movant’s interest must be impaired

by disposition of the litigation without the movant’s

involvement and the movant’s interest must not be represented adequately by any party to the litigation. . . .

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Richardson v. Semple

‘‘For purposes of judging the satisfaction of [the]

conditions [for intervention] we look to the pleadings,

that is, to the motion for leave to intervene and to the

proposed complaint or defense in intervention, and

. . . we accept the allegations in those pleadings as

true. . . . [N]either testimony nor other evidence is

required to justify intervention, and [a] proposed intervenor must allege sufficient facts, through the submitted motion and pleadings, if any, in order to make a

showing of [its] right to intervene. The inquiry is

whether the claims contained in the motion, if true,

establish that the proposed intervenor has a direct and

immediate interest that will be affected by the judgment. . . .

‘‘[T]he four factors of the intervention as of right test

are viewed in a slightly different lens when determining

the jurisdictional issue of whether the proposed intervenor has made a colorable claim to intervene as of right.

. . . Consistent with the well established rule that

every presumption is to be indulged in favor of jurisdiction, and the judicial policy preference to bring about

a trial on the merits of a dispute whenever possible

and to secure for the litigant his day in court . . . our

examination of whether a colorable claim exists focuses

on the plausibility of the appellant’s challenge to the

denial of the motion to intervene when the pleadings

and motion are viewed in light of the relevant legal

principles.’’ (Citations omitted; emphasis omitted; internal quotation marks omitted.) Id., 231–33. ‘‘Failure to

meet any one of the four elements, however, will preclude intervention as of right.’’ BNY Western Trust v.

Roman, 295 Conn. 194, 206, 990 A.2d 853 (2010).

In the present case, the ACLU failed to identify in its

motion to intervene a direct and substantial interest in

the disclosure of the video recording that is different

from the interest of any member of the general public.

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Richardson v. Semple

Indeed, in support of its motion to intervene, it represented that its intervention was necessary to advocate

for public access to the video recording. On appeal, the

ACLU further contends that its ‘‘interests in intervening

here . . . go beyond the general public’s interest in

open courts because they have ripened into justiciable

legal injuries on which it seeks a ruling.’’ The ACLU

argues that it ‘‘has a specific, personal and legal interest

in the issue of whether the [video recording] may be

lawfully sealed, as opposed to a general interest that

all members of the community share, because it has

asked for a copy of the record and been denied.’’ This

argument is misplaced in that the ACLU did not attain

a direct and substantial interest in the subject matter

of this case simply because it sought and was denied

access to the video recording.5 By that logic, anyone

who sought and was denied access to the video

recording would share that same purported interest and

therefore meet the direct and substantial interest prong

of the intervention as of right requirements. We decline

to adopt that circular argument. In its motion to intervene, the ACLU argued that its intervention was necessary to ‘‘vindicate its presumptive right to access’’ to

the video recording. That right is shared by every member of the public.

Although we are mindful that in order to invoke this

court’s jurisdiction a proposed intervenor is required

5

The ACLU relies heavily on this court’s decision in Rosado v. Bridgeport

Roman Catholic Diocesan Corp., 60 Conn. App. 134, 758 A.2d 916 (2000).

In Rosado, this court considered an appeal from the denial of the motion

of seven priests to intervene in an action brought by the plaintiffs against

the Bridgeport Roman Catholic Diocesan Corporation (Diocese) and others

for damages for alleged sexual abuse by a priest when he was assigned to

various churches within the Diocese. Id., 135. This court held that the priests

were entitled to intervene as of right for the purpose of contesting the

disclosure of their private and confidential personnel files on the ground,

inter alia, that those priests had a direct and personal interest in arguing

to protect the release of those files. Id., 148. By contrast, the ACLU in this

case has not identified any direct and substantial interest that differs from

the interest of a member of the public.

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Richardson v. Semple

only to establish a colorable claim that it is entitled to

intervention as of right and not prove that it is so entitled, the ACLU has failed to identify an entitlement to

intervention as of right that is superficially well

founded, let alone such a claim upon which it might

prevail.6 Because the ACLU has failed to make a colorable claim of intervention as of right, the trial court’s

denial of its motion to intervene is not a final judgment

for purposes of this appeal.

The appeal is dismissed.

In this opinion the other judges concurred.

6

Moreover, as the court aptly noted, Practice Book § 11-20A affords all

members of the public the opportunity to be heard when the sealing of a

filing is considered by the court. Indeed, several members of the public,

including counsel for the ACLU, presented their positions to the court at

the sealing hearing.