Justia Connecticut Supreme Court Opinion Summaries

Articles Posted in Civil Procedure

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The Supreme Court reversed the judgment of the trial court rendering summary judgment in favor of Defendants after concluding that Plaintiff's unjust enrichment claims were governed by Delaware law and were thus time-barred, holding that Connecticut law, rather than Delaware law, controlled the timeliness of Plaintiff's claims. Plaintiff brought unjust enrichment claims against Defendants seeking recovery for alleged overpayments issued to Defendants by Plaintiff's putative predecessor in interest pursuant to a limited partnership agreement. The trial court concluded that Plaintiff's claims were governed by Delaware law and were therefore time-barred. The Supreme Court reversed, holding (1) Delaware law governed the substantive rights and liabilities of the parties arising out of the limited partnership agreement, but Connecticut law governed matters of judicial administration and procedure; and (2) because Plaintiff's unjust enrichment claims had a common-law origin, the limitation period properly was characterized as procedural, and therefore, Connecticut law governed the timeliness of Plaintiff's unjust enrichment claims. View "Reclaimant Corp. v. Deutsch" on Justia Law

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The Supreme Court reversed the judgment of the appellate court vacating the trial court's order denying David Salinas's motion for a protective order seeking to prohibit the Town of Redding from taking his deposition, holding that there was no appealable final judgment. Redding Life Care, LLC initiated an action against the Town to challenge the assessed value of real property it owned. The Town served Salinas, who had completed two appraisals of that property, with a subpoena compelling him to appear at a deposition. Salinas filed a motion for a protective order seeking to prohibit the Town from taking his deposition, arguing that he could not be compelled to testify as an expert because Connecticut law prohibited the compulsion of such unretained expert testimony. The trial court denied Salinas' motion. Salinas then filed a writ of error. The appellate court granted the writ. The Supreme Court reversed, holding (1) the trial court's order denying Salinas' motion for a protective order was an interlocutory ruling that normally is not appealable; and (2) the order satisfied neither the first or second prong of State v. Curcio, 463 A.2d 566 (Conn. 1983), and thus did not constitute an appealable final judgment. View "Redding Life Care, LLC v. Town of Redding" on Justia Law

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In certified appeal arising from a consolidated zoning appeal and enforcement action relating to a manufacturing facility the Supreme Court affirmed the decision of the Appellate Court reversing the judgment of the superior court denying proposed intervenors' motions to intervene and remanding the case for further proceedings, holding that the trial court erred in denying the motions to intervene as untimely. Since 1997, the manufacturing facility at issue had been subject to a stipulated judgment imposing various restrictions on its operation. In 2015, the trial court opened and modified the 1997 stipulated judgment by agreement of the parties. The public, however, had been informed that the parties' joint motion to open and modify the judgment would not be heard until one week later. Two proposed intervenors sought to intervene, alleging environmental harm. The trial court denied the motions to intervene as untimely. The Appellate Court reversed, concluding that the trial court's expedited consideration of the motion to open and modify the stipulated judgment violated the proposed intervenors' right to timely, accurate notice and their statutory right to intervene and to participate in the hearing on the stipulated judgment. The Supreme Court affirmed, adopting the Appellate Court's opinion as a proper statement of the issues and applicable law concerning those issues. View "Griswold v. Camputaro" on Justia Law

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The Supreme Court affirmed the judgment of the Appellate Court in this interlocutory appeal regarding what preclusive effective to give in this action to the findings and judgment rendered by an English court in a prior action brought by Plaintiff against the named defendant, holding that the Appellate Court correctly found that none of the parties was entitled to the claimed preclusive effect. The English action resulted in a $243,023,089 judgment, plus interest, against the named defendant, Sebastian Holdings, Inc. Plaintiff, Deutsche Bank AG, later commenced the instant action against Sebastian and Alexander Vik, the sole shareholder and sole director of Sebastian. Plaintiff sought to pierce Sebastian's corporate veil and hold Vik personally liable for his corporation's judgment debt. All parties claimed, unsuccessfully, an entitlement to a preclusive effect as a result of the final judgment rendered in the prior English action. The Appellate Court agreed with the trial court that the parties were not entitled to have this action decided in their respective favor on the basis of the alleged preclusive effect of the English judgment. The Supreme Court adopted the Appellate Court's opinion as the proper statement of the issues and the applicable law concerning those issues and affirmed. View "Deutsche Bank AG v. Sebastian Holdings, Inc." on Justia Law

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The Supreme Court dismissed this writ of error brought by the plaintiffs in error seeking to protect their rights with respect to the judgment of the trial court that was challenged on appeal in Independent Party of CT-State Central v. Merrill, __ A.3d __ (Conn. 2019), holding that the writ of error was moot. In its judgment, the trial court resolved a dispute between the Danbury and Waterbury factions of the state’s Independent Party by granting declaratory and injunctive relief directing Secretary of State Denise W. Merrill to accept only those endorsements made pursuant to the party’s 2010 bylaws. The plaintiffs in error were thirteen candidates for the state House of Representatives endorsed by the Danbury faction prior to the trial court’s decision. The endorsed candidates argued that the writ of error was moot because of the Secretary’s unchallenged decision to accept the Danbury faction’s endorsements with respect to twelve of them. The Supreme Court dismissed this action, holding (1) the writ of error was moot; and (2) the defendant in error’s separate request for relief was not properly before the Court. View "Independent Party of CT-State Central v. Merrill" on Justia Law

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The Supreme Court affirmed the judgment of the trial court for Defendants Michael Telesca and Rocco Frank, Jr. in this battle between the Danbury faction and the Waterbury faction over the control of the state’s Independent Party, holding that the trial court’s decision was timely and that the trial court properly construed Conn. Gen. Laws 9-374. In its decision, the trial court ordered Secretary of State Denise W. Merrill to accept candidate endorsements made pursuant to the 2010 bylaws of the Independent Party of CT-State Central - which, together with its officers, led the Danbury faction and filed the complaint - which, in effect, gave the Waterbury faction control over the Independent Party’s statewide nominations. The Supreme Court affirmed, holding (1) the trial court’s order of supplemental briefing and oral argument concerning its subject matter jurisdiction preserved its personal jurisdiction over the parties by stopping and later restarting the decision period, thus rendering the court’s decision timely; and (2) the trial court properly determined that section 9-374 rendered the 2010 bylaws controlling, as opposed to bylaws that the Danbury faction had previously filed with the Secretary. View "Independent Party of CT-State Central v. Merrill" on Justia Law

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The Supreme Court reversed the judgment of the Appellate Court dismissing the appeal filed by Defendant, a property owner, of the trial court’s determination that Plaintiff, a municipality, was entitled to an award for the attorney’s fees it incurred in a related federal action for lack of a final judgment, holding that the trial court’s determination was an appealable final judgment. The trial court granted Plaintiff’s motion for summary judgment as to liability with respect to the federal action attorney’s fees, concluding that Defendant was liable for the federal action attorney’s fees under Conn. Gen. Stat. 12-161a. Defendant appealed. The Appellate Court dismissed the appeal, concluding that the trial court’s judgment with respect to the federal action attorney’s fees was not an appealable final judgment absent a determination of the amount of the attorney’s fees. The Supreme Court reversed, holding that the trial court’s ruling on the parties’ motions for summary judgment as to liability constituted an appealable final judgment pursuant to the bright line rule articulated in Paranteau v. DeVita, 544 A.2d 634 (1988). View "Town of Ledyard v. WMS Gaming, Inc." on Justia Law

Posted in: Civil Procedure

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The Supreme Court affirmed the trial court’s judgment in favor of Defendant following the grant of Defendant’s motion to strike, holding that an action authorized by the claims commissioner, limited to medical malpractice, may not survive a motion to strike where the plaintiff was not a patient of the defendant, as required by Jarmie v. Troncale, 50 A.3d 802 (2012). Plaintiff, administratrix of the estate of the decedent in this case, sought permission to bring an action against Defendant for medical malpractice based on mental health services and treatment given to Robert Rankin, who allegedly fatally stabbed the decedent. The claims commissioner granted Plaintiff permission to bring an action under Conn. Gen. Stat. 4-160(b), limited to medical malpractice. Plaintiff then brought this action. Defendant filed a motion to strike the complaint, arguing that Connecticut does not recognize medical malpractice claims brought by nonpatient third parties. The trial court granted the motion to strike and then rendered judgment for Defendant. The Supreme Court affirmed, holding (1) Jarmie prohibits an action, limited by the claims commissioner to medical malpractice, where the plaintiff was not a patient of the defendant; and (2) if Plaintiff’s action sounded in negligence, then the trial court lacked subject matter jurisdiction over the claim. View "Levin v. State" on Justia Law

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The Supreme Court affirmed the order of the trial court granting the Commission on Human Rights and Opportunities’ motion to dismiss Plaintiff’s administrative appeal from the Commission’s denial of Plaintiff’s motion to dismiss an employment discrimination complaint brought by a former female employee, holding that the Commission’s denial of Plaintiff’s motion to dismiss was not an immediately appealable order. A former female employee of Plaintiff, a religious school, filed a complaint with the Commission alleging that Plaintiff had wrongfully terminated her employment on the basis of her sex, marital status, and pregnancy. Plaintiff moved to dismiss the complaint, arguing it was immune from employment discrimination actions under the ministerial exception to employment discrimination laws. The Commission denied Plaintiff’s motion to dismiss, and Plaintiff appealed. The trial court granted the Commission’s motion to dismiss. The Supreme Court affirmed, holding that the trial court correctly determined that Plaintiff had failed to make a colorable claim of immunity under Conn. Gen. Stat. 52-571b(d) and, therefore, the Commission’s denial of Plaintiff’s motion to dismiss the employment discrimination complaint was not an immediately appealable order. View "Trinity Christian School v. Commission on Human Rights & Opportunities" on Justia Law

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Plaintiff’s collateral attack on Sowell v. DiCara, 127 A.3d 356 (Conn. App. Ct. 2015), cert. denied, 128 A.3d 953 (Conn. 2015), in this declaratory judgment action was nonjusticiable under Valvo v. Freedom of Information Commission, 985 A.2d 1052 (Conn. 2010). Plaintiff filed a writ error (first writ) claiming that a judge had improperly found clear and convincing evidence that he had violated Rule 4.2 of the Rules of Professional Conduct. The Appellate Court found that Plaintiff had violated Rule 4.2 and dismissed the first writ. Thereafter, Plaintiff filed a writ of error in the Supreme Court challenging the Appellate Court’s actions (second writ). The Appellate Court dismissed the second writ. Plaintiff then filed the present action against a law firm and the Appellate Court claiming that the Appellate Court’s construction of Rule 4.2 was a due process violation. The trial court granted Defendants’ motion to dismiss, concluding that the claims against the Appellate Court were barred by sovereign immunity. On appeal, Plaintiff claimed that the trial court erred in concluding that Plaintiff’s challenge to the Appellate Court’s interpretation of Rule 4.2 in Sowell was barred by the doctrine of sovereign immunity. The Supreme Court affirmed on the alternative ground that Plaintiff’s collateral attack on Sowell was nonjusticiable under Vavlo. View "Mendillo v. Tinley, Renehan & Dost, LLP" on Justia Law