Justia Connecticut Supreme Court Opinion SummariesArticles Posted in Contracts
Hassett v. Secor’s Auto Center, Inc.
In this Connecticut case, the plaintiff, Erin C. Hassett, purchased a used motor vehicle from the defendant, Secor’s Auto Center, Inc., and experienced mechanical problems shortly after the purchase. The plaintiff claimed the defendant breached its warranty by refusing to make necessary repairs and, as a result, she revoked her acceptance of the vehicle. The plaintiff brought legal action against the defendant, alleging breach of warranty and revocation of acceptance under statute § 42a-2608. The jury found in favor of the plaintiff, including on her revocation of acceptance claim, awarding her $11,000 in damages.The plaintiff then moved for additur, requesting a refund of the full purchase price of the vehicle in addition to the $11,000 award. The trial court denied the motion, and the Appellate Court upheld the trial court’s decision. The plaintiff appealed to the Supreme Court of Connecticut, arguing that she was entitled to the $11,000 award plus a refund of the full purchase price because the jury found in her favor on her revocation of acceptance claim.The Supreme Court affirmed the Appellate Court’s decision, concluding that the trial court had not abused its discretion in denying the plaintiff’s motion for additur. The court found that the issue of revocation of acceptance damages had been submitted to the jury as a matter of disputed fact. The jury's award of $11,000 was determined to represent revocation of acceptance damages equivalent to its determination of "so much of the price as had been paid" in accordance with § 42a-2-711 (1). The plaintiff's argument that the court should have determined the proper measure of revocation of acceptance damages post-verdict was rejected. The court found that the plaintiff's dissatisfaction with the verdict did not constitute grounds to award her the full purchase price of the vehicle as a matter of law. View "Hassett v. Secor's Auto Center, Inc." on Justia Law
Tilsen v. Benson
The Supreme Court affirmed the judgment of the trial court dissolving Plaintiff's marriage to Defendant, holding that Plaintiff was not entitled to relief on his allegations of error.At issue in this case was the extent to which a Connecticut court may enforce the terms of a "ketubah," a contract governing marriage under Jewish law. The trial court in this case denied Plaintiff's motion to enforce the terms of the parties' ketubah as a prenuptial agreement on the ground that doing so would be a violation of the First Amendment to the United States constitution. The Supreme Court affirmed, holding (1) the trial court properly denied Plaintiff's motion to enforce the ketubah; and (2) the trial court's alimony order, considered in light of Plaintiff's net earning capacity, was not an abuse of discretion. View "Tilsen v. Benson" on Justia Law
High Watch Recovery Center, Inc. v. Dep’t of Public Health
The Supreme Court reversed the judgment of the appellate court affirming the judgment of the superior court dismissing for lack of jurisdiction High Watch Recovery Center, Inc.'s administrative appeal challenging the decision of the Department of Public Health approving a certificate of need application submitted by Birch Hill Recovery Center, LLC, holding that the appellate court erred.Birch Hill submitted a certificate of need application to the Office of Health Care Access requesting public approval to establish a substance abuse treatment facility in Kent. The Department and Birch Hill entered into an agreed settlement constituting a final order wherein the Department approved Birch Hill's application subject to certain conditions. High Watch, which operated a nonprofit substance abuse treatment facility, intervened and appealed the final order. The superior court dismissed the appeal on the grounds that the Department's decision was not a final decision in a contested case and that High Watch was not aggrieved by the decision. The appellate court affirmed. The Supreme Court reversed, holding that the appellate court did not err in determining that High Watch's petition requesting intervenor status in the public hearing on Birch Hill's certificate of need application was not a legal sufficient request for a public hearing for the purposes of Conn. Gen. Stat. 19a-639a(e). View "High Watch Recovery Center, Inc. v. Dep't of Public Health" on Justia Law
Deutsche Bank AG v. Sebastian Holdings, Inc.
The Supreme Court affirmed the judgment of the trial court declining to pierce Sebastian Holdings, Inc.'s (SHI) corporate veil and to hold Alexander Vik, SHI's sole shareholder and director, jointly and severally liable with SHI for an approximately $243 million foreign judgment against Vik, holding that the trial court did not err.After SHI failed to pay the English judgment Deutsche Bank commenced this action against Defendants alleging that Vik caused SHI to breach its contractual obligations to Deutsche Bank and to fraudulently convey funds to third parties in order to defraud Deutsche Bank out of money owed. Count two sought a declaratory judgment piercing SHI's corporate veil and holding Vik jointly and severally liable for the English judgment. The trial court rendered judgment for Defendants. The Supreme Court affirmed, holding that Deutsche Bank could not prevail on its claim that the results of the trial would have been different if the court had applied Connecticut law or if it had correctly applied the laws of Turks and Caicos Islands, a British territory. View "Deutsche Bank AG v. Sebastian Holdings, Inc." on Justia Law
Pryor v. Brignole
The Supreme Court reversed the judgment of the appellate court dismissing Defendants' appeals from the order of the trial court denying their specials motions to dismiss the underlying civil action brought against them by Plaintiff, holding that a trial court's denial of a colorable special motion to dismiss filed pursuant to Conn. Gen. Stat. 52-196a is an appealable final judgment under State v. Curcio, 453 A.2d 566 (Conn. 1983).Plaintiff brought this action against claiming that Defendants breached a nondisparagement provision of the parties' settlement agreement, caused him to suffer economic damages, and deprived him of the benefit of the agreement. Defendants filed separate special motions to dismiss the action as a SLAPP suit pursuant to Conn. Gen. Conn. 52-196a. The trial court denied the special motions. The appellate court reversed and granted Plaintiff's motions to dismiss. The Supreme Court reversed, holding that the trial court's denial of Defendants' colorable special motions to dismiss constituted an appealable final judgment under State v. Curcio, 463 A.2d 566 (Conn. 1983). View "Pryor v. Brignole" on Justia Law
Reserve Realty, LLC v. Windemere Reserve, LLC
The Supreme Court affirmed the judgments of the appellate court determining that the four exclusive commercial real estate listing agreements at issue in this case were unenforceable, holding that the appellate court decided that issue correctly.When this case was first brought to the Supreme Court, the Court held that the listing agreements did not violate state antitrust law. On remand for consideration of the remaining grounds on which Defendants had prevailed at trial, the appellate court concluded that the listening agreements incorrectly failed to specify the duration of the brokerage authorization, as required by Conn. Gen. Stat. 20-325a(b) and/or (c), thus rendering them unenforceable. The Supreme Court affirmed, holding (1) the listing agreements complied with the statutory durational requirement; (2) the agreements were personal service contracts requiring the personal performance of the named broker, who died in January 2013; and (3) therefore, Defendants were not liable to Plaintiffs. View "Reserve Realty, LLC v. Windemere Reserve, LLC" on Justia Law
Strazza Building & Construction, Inc. v. Harris
The Supreme Court affirmed the judgment of the appellate court affirming the judgment of the trial court denying a property owner's motion for summary judgment in the underlying dispute with a contractor arising from a construction project, holding that the trial court correctly denied Defendants' motion for summary judgment.Defendants hired Plaintiff to serve as a general contractor to renovate a home located on Greenwich property. Defendants later terminated their contractual relationship with Plaintiff. Plaintiff served mechanics' liens on Defendants and brought this action to foreclose its lien. Defendants moved for summary judgment, arguing that the trial court was required to give res judicata effect to the findings of the trial court in a prior action between Plaintiff and one of Defendants' subcontractors. The trial court denied Defendants' summary judgment motion, determine that all four required elements of res judicata were not met. The appellate court affirmed. The Supreme Court affirmed, holding that the appellate court did not err in holding that the presumption of privity that the Supreme Court held to apply in Girolametti v. Michael Horton Associates, Inc., 208 A.3d 1223 (Conn. 2019), did not apply to the instant case. View "Strazza Building & Construction, Inc. v. Harris" on Justia Law
Hartford Fire Insurance Co. v. Moda, LLC
The Supreme Court affirmed the decision of the trial court granting summary judgment in favor of Insurer in this action brought to determine whether business losses suffered during the COVID-19 pandemic were covered by the relevant policies, holding that Insured's losses were not covered by the two insurance policies at issue.Before the pandemic, Insurer sold two insurance policies to Insured. Insurer later initiated this action seeking a judgment declaring that Insured's business losses incurred during the COVID-19 pandemic were not covered under the policies. The trial court concluded that there was no coverage under either policy. The Supreme Court affirmed, holding that the trial court properly entered summary judgment for Insurer because Insured's losses plainly and unambiguously were not covered by either policy. View "Hartford Fire Insurance Co. v. Moda, LLC" on Justia Law
Connecticut Dermatology Group, PC v. Twin City Fire Insurance Co.
The Supreme Court affirmed the judgment of the trial court in this dispute over whether a property insurance policy providing coverage for "direct physical loss of or physical damage to" covered property provided coverage for business income losses arising from the suspension of business operations during the COVID-19 pandemic, holding that the trial court correctly granted Defendant's motion for summary judgment.Plaintiffs, who suspended their business operations during the COVID-19 pandemic and consequently lost business income and incurred other expenses, filed claims for losses with Defendants. After Defendants denied the claims Plaintiffs brought this actin seeking a judgment declaring that the relevant insurance policies covered their economic losses under the circumstances. The trial court granted summary judgment for Defendants. The Supreme Court affirmed, holding that because Plaintiffs did not suffer any "direct physical loss" of covered property, there was no genuine issue of material fact as to whether the policies did not cover Plaintiffs' claims. View "Connecticut Dermatology Group, PC v. Twin City Fire Insurance Co." on Justia Law
State v. Brandon
The Supreme Court affirmed the judgment of the trial court denying Defendant's motion to suppress statements he had made during two separately recorded interrogations of him by police officers, holding that the trial court properly denied Defendant's motion to suppress.The two interrogations at issue occurred on the same day. As to the first interrogation, Defendant claimed that the police failed to advise him of his rights pursuant to Miranda v. Arizona, 384 U.S. 436 (1966). Defendant further claimed that the second interrogation was tainted by the alleged illegality of the first interrogation. The trial court denied the motion to suppress and, following a jury trial, convicted Defendant of manslaughter in the first degree with a firearm. The Supreme Court affirmed, holding (1) Miranda warnings were not required for the first interrogation because it was not custodial; and (2) the failure to provide the warnings did not taint the second interrogation. View "State v. Brandon" on Justia Law