Justia Connecticut Supreme Court Opinion Summaries

The parties in this case entered into a written contract under which Plaintiff, a contractor, agreed to install a fence around real property owned by Defendant. Defendant paid a deposit of half of the amount due upon execution of the contract but refused to pay the balance owed on the contract upon substantial completion of the fence. Plaintiff sued Defendant. In his answer, Defendant alleged he was not liable under the contract because Plaintiff failed to comply with the Home Improvement Act by failing to indicate a starting and completion date in the contract. The trial court rendered judgment in favor of Plaintiff, concluding that the contract did not comply with the Act but that Defendant invoked the Act in bad faith. The appellate court reversed the award of attorney's fees, costs, and interest, but otherwise directed judgment in favor of Plaintiff for the balance due under the bad faith doctrine. The Supreme Court affirmed, holding that, under these circumstances, the trial court did not abuse its discretion in ordering Defendant to pay Plaintiff the balance due. View "Walpole Woodworkers, Inc. v. Manning" on Justia Law

This case arose out of a motor vehicle accident caused by an underinsured motorist in which Plaintiff, an employee of defendant City (Defendant), sustained injuries while operating a private passenger motor vehicle owned by Defendant and acting within the scope of his employment. Plaintiff sought coverage for his remaining damages from Defendant pursuant to its obligation to provide underinsured motorist coverage pursuant to Conn. Gen. Stat. 38a-336(a)(2). Defendant denied Plaintiff's claim because Plaintiff's $50,000 recovery exceeded the purported $20,000 coverage limit of Defendant's plan. The trial court rendered in favor of Defendant, determining the limits of Defendant's underinsured motorist coverage in its capacity as a self-insurer to be the statutory minimum of $20,000 per person and $40,000 per occurrence. The Supreme Court affirmed, albeit under different reasoning, holding that pursuant to the statutory insurance scheme, a self-insurer is deemed to provide the minimum statutory underinsured motorist coverage of $20,000 per accident and $40,00 per occurrence for the benefit of occupants of its private passenger motor vehicles. View "Garcia v. Bridgeport" on Justia Law

This case, which involved the summary suspension of the medical privileges of Plaintiff by Defendant, Bradley Memorial Hospital and Health Center, Inc., came to the Supreme Court for the second time. In Plaintiff's appeal, the Court reversed the judgment of the trial court granting Defendant's motion for judgment notwithstanding the verdict and denying Plaintiff's motion for punitive damages. On remand, Plaintiff was awarded punitive damages and offer of judgment interest. Defendant appealed. The Supreme Court reversed the judgment, holding that Defendant was entitled to immunity as a matter of law under the federal health Care Quality Improvement Act from money damages arising from its summary suspension of Plaintiff's privileges. Remanded with direction to render judgment in favor of Defendant. View "Harris v. Bradley Mem'l Hosp. & Health Ctr., Inc." on Justia Law

The parcel of land that was the subject of this appeal was once owned by a school. An adjacent property, now owned by Defendants, Eric and Wendy Federer, was previously owned by Wendy's father. In 1990, the school sold its property to a limited liability corporation subject to a set of restrictive covenants that did not expressly reference any third parties. The present action arose when Plaintiff, the current owner of the property, sought permits to develop the school property in a manner inconsistent with the terms of the restrictive covenants. Plaintiff filed a declaratory judgment action seeking to establish the unenforceability of the restrictive covenants as to Defendants. Defendants counterclaimed, seeking to quiet title to Plaintiff's property and to enforce the restrictive covenants. The trial court granted summary judgment in favor of Plaintiff. The Supreme Court reversed, holding (1) the covenants at issue in this case were not void as a matter of law; and (2) questions of material fact existed as to whether Defendants were entitled to enforce them. Remanded. View "Wykeham Rise, LLC v. Federer" on Justia Law

This appeal and cross appeal concerned the authority of the named defendant, the city of Waterbury, under its city charter to offset the pension benefits of Plaintiffs, several individuals who had worked for the city, by the heart and hypertension benefits they received. The trial court rendered judgment in favor of Plaintiffs on their breach of contract claims. The Supreme Court reversed in part and directed judgment in favor of Defendants on all claims except Nicolas Russo's claim for breach of contract, and remanded the case for a new trial on that claim, holding (1) the trial court improperly concluded, with respect to all of Plaintiffs except Russo, their respective collective bargaining agreements conflicted with the Waterbury city charter, which allowed the city to offset Plaintiff's pension benefits based on their heart and hypertension benefits; and (2) although the trial court properly interpreted Russo's collective bargaining agreement to permit the city to offset his pension benefits by his heart and hypertension benefits, the court improperly failed to determine whether Russo's combined pension and heart and hypertension benefits exceeded the cap set forth in the agreement, thus permitting an offset. View "Russo v. Waterbury" on Justia Law

David Caron purchased a majority membership in Goodhall's Chrysler-Plymouth-Dodge-Jeep-Eagle, LLC without having obtained the written consent of Goodhall's, Inc. (Goodhall's), in violation of Goodhall's lease with Goodhall's Chrysler-Plymouth-Dodge-Jeep-Eagle. The lease idenitified Goodhall's as the landlord and Goodhall's Chrysler-Plymouth-Dodge-Jeep-Eagle as the tenant. After a dispute arose concerning the party responsible for remediating certain environmental conditions on the property, Plaintiffs, David Caron and David Caron Chrysler Motors, filed suit against Defendants, Goodhall's and others, claiming that Defendants had violated provisions of its lease regarding Goodhall's responsibility for preexisting environmental conditions and Goodhall's warranty of fitness and habitability. The trial court rendered judgment in favor of Defendants, concluding that no contract existed between the parties to this action because the assignment of the majority interest in the tenant to Caron was invalid. The appellate court affirmed. The Supreme Court reversed, holding (1) the appellate court improperly failed to consider Plaintiffs' claim that the trial court had improperly concluded that no contract existed between David Caron Chrysler Motors and Goodhall's; and (2) the trial court was incorrect in finding that, because Goodhall's did not consent to the assignment, there was no contract between David Caron Chrysler Motors and Goodhall's. View "David Caron Chrysler Motors, LLC v. Goodhall's, Inc." on Justia Law

The predecessor insurance companies to Plaintiff, Arrowood Indemnity Company, brought a declaratory judgment action in the U.S. district court claiming they did not have a duty to defend or to indemnify Defendants, the King family, for liability arising out of injuries sustained by a third party while the King's child was driving his parents' ATV on a private road in a private residential community, claiming that the accident had not occurred on an insured location and the Kings' notice of a claim was untimely. The district court rendered summary judgment in favor of Plaintiff. The Supreme Court accepted certification to answer questions of unresolved state law and concluded (1) with respect to a claim for negligent entrustment under a liability policy that provides coverage for accidents involving ATVs that occur on insured locations, the relevant location is the site of the accident; (2) the private road in this case did not fall under the coverage provision; and (3) social interactions between the insured and the claimant making no reference to an accident do not justify delayed notice, but an insurer must prove prejudice to disclaim its obligation to provide coverage based on untimely notice. View "Arrowood Indem. Co. v. King" on Justia Law

Two houseguests suffered serious injuries after their host left her car running overnight in an attached garage and the house filled with carbon monoxide. Plaintiff, the insurer with whom the homeowner had a homeowner's insurance policy, brought a declaratory judgment action against Defendants, the homeowner, the houseguests, and the homeowner's automobile insurer, seeking a declaration that the homeowner's policy did not cover the injuries suffered by the houseguests. The trial court granted summary judgment in favor of Plaintiff, finding that the policy did not cover the injuries because they fell within the policy exclusion for injuries arising out of the use of a motor vehicle. The Supreme Court affirmed, holding that the injuries suffered by the houseguests fell under the policy's motor vehicle exclusion. View "New London County Mutual Ins. Co. v. Nantes" on Justia Law

Plaintiff divorced his wife (Wife) after discovering she had had an extramarital affair with Defendant and had conceived a child (Child) with him. After Plaintiff and Wife divorced, Plaintiff brought an action against Defendant, seeking damages on claims of nondisclosure, misrepresentation, and unjust enrichment. Specifically, Plaintiff sought reimbursement from Defendant for the costs he had expended in raising Child from her birth until his divorce from Wife, when Child was almost fifteen years old. The trial court concluded that although Defendant was Child's biological father, the doctrine of equitable estoppel and public policy concerns precluded Plaintiff from pursuing his claims for reimbursement and denying his paternity. The Supreme Court reversed the judgment of the trial court, holding that the court improperly found that Plaintiff was equitably estopped from pursuing his claims because there was insufficient evidence of financial harm to Child, which is required to establish the element of detrimental reliance in a case involving a denial of paternity. View "Fischer v. Zollino" on Justia Law

Plaintiff, a development company, brought an action against Defendants, several entities including the City, alleging Defendants had violated the Connecticut Antitrust Act by engaging in an illegal conspiracy in restraint of trade. The trial court granted Defendants' motion to strike Plaintiff's amended complaint on the ground that the complaint failed to allege an antitrust injury. The appellate court affirmed. The Supreme Court affirmed, holding that Plaintiff's allegation that Defendants took bribes and kickbacks in exchange for steering public contracts did not state a cognizable antitrust claim, and therefore, the appellate court and trial court properly granted Defendants' motions to strike Plaintiff's amended complaint. View "Bridgeport Harbour Place I, LLC v. Ganim" on Justia Law