Justia Connecticut Supreme Court Opinion Summaries

Articles Posted in Contracts
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The Supreme Court reversed the judgments of the Appellate Court determining that it was required to apply State v. Hossan-Maxwell, Inc., 436 A.2d 284 (Conn. 1980), to this case, holding that Hossan-Maxwell, Inc. is overruled.Plaintiffs and Defendants entered into agreements for the sale of property. Defendants included list-back provisions in their purchase and sale agreements for two parcels. Plaintiffs later filed suit alleging breach of contract and anticipatory breach. Defendants raised several defenses, arguing, as relevant to this appeal, that the list-back provisions in the parties' purchase and sale agreements were illegal tying arrangements. The trial court ruled for Defendants. The Appellate Court affirmed on the basis of the antitrust defense. The Supreme Court reversed, holding (1) the trial court should not have found the list-back agreements unenforceable without first engaging in a full market analysis, as a per se ban on list-back agreements, as applied in Hossan-Maxwell, Inc. is inconsistent with federal antitrust law as it has evolved over the decades; and (2) the trial court's judgments cannot be affirmed under the proper legal standard. View "Reserve Realty, LLC v. Windemere Reserve, LLC" on Justia Law

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In this breach of contract action, the Supreme Court reversed in part the trial court's judgment rendered in favor of Plaintiff as to his derivative claims, holding that Plaintiff lacked standing to bring them under the common law or the Connecticut Limited Liability Company Act, Conn. Gen. Stat. 34-100 et seq., but affirmed the judgment for Plaintiff as to his direct claims.This case arose from the deterioration of a business relationship between three individuals. Plaintiff sought damages for, inter alia, breach of contract. Defendants filed a counterclaim. The trial court awarded judgment in part for Plaintiff on the complaint and on the counterclaim. The Supreme Court reversed in part and vacated the court's award of attorney fees under the Connecticut Unfair Trade Practices Act, Conn. Gen. Stat. 42-110a et seq., holding (1) Plaintiff lacked standing to bring his derivative claims; and (2) the trial court properly entered judgment for Plaintiff on his direct counts and did not abuse its discretion in refusing to order Defendants to reimburse Plaintiff for the fees incurred by a joint, court-appointed fiduciary hired to wind up the companies at issue. View "Saunders v. Briner" on Justia Law

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In this case concerning how pre-embryos created through in vitro fertilization should be distributed upon the divorce of their progenitors the Supreme Court reversed the trial court's judgment insofar as the court determined that a storage agreement with the fertility clinic was not enforceable, holding that the parties in this case had an enforceable agreement.Plaintiff and Defendant underwent in vitro fertilization during their marriage, and several pre-embryos resulting from that treatment were stored for implantation at a later date. As part of the storage agreement, the parties stated that they wanted the pre-embryos discarded if they divorced. The parties later divorced, and Plaintiff sought to have the pre-embryos discarded. Defendant, however, wanted the pre-embryos preserved or donated, arguing that the agreement was unenforceable. The trial court determined that the agreement was unenforceable and awarded the pre-embryos to Plaintiff. The Supreme Court reversed, holding that the trial court incorrectly determined that the storage agreement was unenforceable. View "Bilbao v. Goodwin" on Justia Law

Posted in: Contracts, Family Law
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In this breach of contract and negligent infliction of emotional distress action the Supreme Court affirmed the appellate court's judgment affirming the trial court's judgment denying Defendant's motion for judgment notwithstanding the verdict, holding that there was sufficient evidence to support the jury's verdict for Plaintiff.This action stemmed from Defendant's handling of Plaintiff's homeowner's insurance claim. The jury returned a verdict for Plaintiff on both counts. Defendant filed a motion for judgment notwithstanding the verdict, renewing its motion for a directed verdict, arguing that the verdict was not supported by sufficient evidence presented during Plaintiff's case-in-chief. The trial court denied the motion. On appeal, Defendant contended that the so-called waiver rule - which provides that a defendant waives the right to appeal the trial court's denial of the defendant's motion for directed verdict at the close of the plaintiff's case by opting to introduce evidence in its own behalf - is inapplicable to civil cases in which a trial court reserves decision on a motion for directed verdict. The Supreme Court disagreed, holding that a court reviewing the sufficiency of the evidence to support a jury's verdict must consider all of the evidence considered by the jury returning the verdict, not just the evidence presented in the plaintiff's case-in-chief. View "Riley v. Travelers Home & Marine Insurance Co." on Justia Law

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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 affirmed in part and reversed in part the judgment of the trial court insofar as it rendered judgment in Defendant's favor on counts alleging fraudulent transfer under the Connecticut Uniform Fraudulent Transfer Act (CUFTA), Conn. Gen. Stat. 52-552a through 52-552l, and unjust enrichment, holding that the trial court erred in rejecting Plaintiff's CUFTA claim but did not err in rejecting Plaintiff's unjust enrichment claim.Defendant Stephen McGee used a power of attorney granted to him by his elderly mother, Helen McGee, to transfer to himself funds from Helen's checking account. As a consequence of the transfers, Helen had insufficient assets to pay her debt to Plaintiff Geriatrics, Inc. Plaintiff brought this action, and the trial court rendered judgment in Defendant's favor on Plaintiff's CUFTA and unjust enrichment claims. The Supreme Court reversed in part, holding (1) in rejecting the CUFTA claim the trial court improperly failed to consider and apply agency principles; and (2) in light of the unrequited evidence, the trial court did not abuse its discretion in rejecting Plaintiff's unjust enrichment claim. View "Geriatrics, Inc. v. McGee" on Justia Law

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The Supreme Court reversed in part the judgment of the trial court against Defendants in this public nuisance suit, holding that Defendants' contractual undertaking with the Connecticut Department of Transportation (DOT) did not create a duty to Plaintiffs.Project Service, LLC, the named defendant, and the DOT, which owned a service plaza, had entered into a concession agreement which imposed the responsibility on Project Service to operate and maintain the service plaza. Project Service contracted the day-to-day operation of the service plaza to one defendant, which subcontracted certain operations to another defendant. Plaintiffs alleged that Defendants created a public nuisance by permitting the tortfeasor to consume alcohol and loiter on the service plaza premises before driving his Jeep onto a roadway where he killed and injured the victims. Plaintiffs also alleged that Defendants breached a duty to passing motorists to protect them from the increased risk of harm created by Defendants' failure to perform their contractual obligations. The trial court rendered summary judgment on the nuisance claims, and the jury returned a verdict in Plaintiffs' favor on Plaintiffs' negligence claims. The Supreme Court reversed in part, holding (1) Defendants' agreement did not create a duty to Plaintiffs; and (2) Plaintiffs' public nuisance claims failed as a matter of law. View "Demond v. Project Service, LLC" on Justia Law

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The Supreme Court affirmed the judgment of the trial court granting Defendants’ motion to dismiss this claim brought by trust beneficiaries against third parties on behalf of the trust, holding that the trial court properly determined that it lacked subject matter jurisdiction over Plaintiffs’ claim.Plaintiffs, beneficiaries of a trust, brought a breach of contract claim against Defendants, the financial advisor for the trust and the advisor’s employee. Plaintiffs argued that they fit within an exception to the general rule that beneficiaries of a trust lack standing to bring an action against a third party for liability to the trust, thus allowing them to bring this action because trustee improperly refused or neglected to do so. The trial court granted Defendants’ motion to dismiss. The Supreme Court affirmed, holding that Plaintiffs failed to demonstrate that the trustee improperly failed to sue Defendants for their alleged breach, and therefore, the allegations were insufficient to demonstrate that Plaintiffs had standing to sue. View "Browning v. Van Brunt, DuBiago & Co., LLC" on Justia Law

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In this consolidated action, the Supreme Court held that the trial court did not abuse its discretion in ordering class certification.Plaintiffs, service station operators and franchised dealers for gasoline products supplied by Defendant, a wholesale supplier, commenced this putative class action alleging that the proposed class members had been overcharged. Defendant then commenced a separate action against one of the plaintiffs. In response, that plaintiff filed a counterclaim styled as a proposed class action that mirrored Plaintiffs’ complaint in the earlier action. The trial court solicited the two actions and then allowed the action to proceed as a class action. Defendant appealed from the orders certifying the class. The Supreme Court affirmed, holding that the trial court did not abuse its discretion in ordering class certification. View "Standard Petroleum Co. v. Faugno Acquisition, LLC" on Justia Law

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Exercising jurisdiction over Defendant-insurer under the circumstances of this case was permitted by Connectictut’s corporate long arm statute, Conn. Gen. Stat. 33-929(f)(1), and comported with the due process clause of the Fourteenth Amendment.Defendant issued an automobile insurance policy covering a vehicle driven by Insured. The policy was written in New York at Defendant’s principal place of business, and Defendant did not direct or participate in any business transactions in Connecticut at the time. The coverage territory of the policy included Connecticut. Insured’s vehicle later collided with a vehicle occupied by Plaintiffs. A judgment was rendered against Insured in favor of Plaintiffs. Defendant failed to defend Insured or to indemnify him for the judgment rendered against him. Plaintiffs then brought this action against Defendant. Defendant moved to dismiss the action for lack of personal jurisdiction. The trial court granted the motion to dismiss. The Supreme Court reversed, holding that Defendant’s agreement to defend and indemnify Insured established personal jurisdiction under the long arm statute and that subjecting Defendant to the jurisdiction of this state comported with the due process clause of the Fourteenth Amendment. View "Samelko v. Kingstone Insurance Co." on Justia Law