Justia Connecticut Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the trial court concluding that enforcement of the prenuptial agreement between the parties was not unconscionable, with one exception, holding that the trial court did not err in ruling that the occurrence of the unforeseen events did not render the enforcement of the entire agreement unconscionable at the time of the dissolution.In 2010, shortly before the parties' marriage they executed a prenuptial agreement. In 2016, Plaintiff brought this action seeking dissolution of the marriage and enforcement of the prenuptial agreement. Defendant filed a cross-claim, asserting that the agreement was unenforceable because it was unconscionable at the time of the dissolution under Conn. Gen. Stat. 46b-36g(a)(2). The trial court dissolved the marriage and enforced the terms of the prenuptial agreement with the exception of an attorney's fees provision. The Supreme Court affirmed, holding that the trial court properly allowed the parties the benefit of their agreed-upon, pre-marriage bargain. View "Grabe v. Hokin" on Justia Law

The Supreme Court affirmed the judgment of the trial court seeking to enforce a California judgment or, alternatively, to recover under the theories of breach of contract or quantum meruit, holding that the trial court did not err in rendering judgment in favor of Plaintiff.This case arose out of a dispute arising in connection a contract for the design, decoration, and staging for sale of Defendants' home. Plaintiff, a California company, obtained a default judgment against Defendants and thereafter filed an action in the superior court seeking to enforce the California judgment or to recover under the theories of breach of contract or quantum meruit. The trial court rendered judgment for Plaintiff on the count seeking to enforce the California judgment and in favor of Plaintiff on the breach of contract count. The Supreme Court affirmed, holding (1) the trial court correctly enforced the California judgment against Defendant; (2) the trial court correctly determined that the agreement was not subject to the notice of cancellation provisions in the Home Solicitation Sales Act, Conn. Gen. Stat. 42-134a et seq., (3) the damages award was proper. View "Meribear Productions, Inc. v. Frank" on Justia Law

In this case coming to the Supreme Court on certification from a federal district court, the Court was asked to decide questions regarding Conn. Gen. Stat. 52-572g. The Court answered the questions as follows: (1) "the amount of indebtedness then outstanding in connection with the credit transaction" is the amount of indebtedness outstanding at the time of the buyer's written demand on the seller for purposes of limiting an assignee's liability under section 52-572g; (2) an assignee can avoid liability under the statute only if the promissory note, contract, or other instrument is reassigned back to the seller prior to the buyer making such a demand; and (3) if a retail installment contract includes the Federal Trade Commission "holder rule" language mandated by 16 C.F.R. 433.2, an assignee's liability under that rule is cumulative to its liability under section 52-572g. View "Hernandez v. Apple Auto Wholesalers of Waterbury, LLC" on Justia Law

The Supreme Court reversed in part the judgment of the trial court awarding postjudgment, offer of compromise interest to Plaintiff under Conn. Gen. Stat. 52-192a and Practice Book 17-18, holding that the trial court's award of postjudgment, offer of compromise interest was improper.Plaintiff, an employment staffing agency that providers workers for temporary assignments, commenced this action against Defendant to recover a debt by filing a complaint for breach of contract and unjust enrichment. The trial court entered judgment in favor of Plaintiff and awarded Plaintiff interest. On appeal, Defendant argued that the trial court's award of postjudgment interest under section 52-192a and Practice Book 17-18 was improper. The Supreme Court reversed the judgment as to the award of postjudgment interest under section 52-192a, holding that the award of post judgment, offer of compromise interest was improper under Gionfriddo v. Avis Rent A Car system, Inc., 472 A.2d 316 (Conn. 1984). View "Kelly Services, Inc. v. Senior Network, Inc." on Justia Law

The Supreme Court affirmed the judgment of the trial court denying Defendant's motion to set aside the jury's verdict in this breach of contract action on the grounds that the terms of the underlying contract precluded such relief, holding that there was no error.Plaintiff, a general contractor, entered into a contract with Defendant, a subcontractor, to provide services related to the installation of drywall and trim. Plaintiff later filed this action alleging that Defendant breached the contract by abandoning performance. The jury found Defendant liable and awarded Plaintiff $45,374. Defendant appealed, arguing that the trial court committed reversible error by declining to set aside the jury's award. The Supreme Court affirmed, holding that Defendant failed to meet its burden of demonstrating that the jury could not have reasonably reached the verdict that it did. View "Viking Construction, Inc. v. TMP Construction Group, LLC" on Justia Law

The Supreme Court reversed the judgment of the trial court in favor of Plaintiffs on all counts in this commercial dispute, holding that the trial court failed properly to instruct the jury regarding the legal effects of the parties' contract in this case and the proper means of calculating damages.Plaintiffs brought this action alleging promissory estoppel, negligent misrepresentation, tortious interference with business expectancies, and violations of the Connecticut Unfair Trade Practices Act (CUTPA), Con. Gen. Stat. 42-110a et seq., and seeking damages, injunctive relief, and attorney fees and costs. The jury returned a verdict for Plaintiffs on all counts. The Supreme Court reversed, holding (1) there was sufficient evidence for the jury to find Defendants liable; but (2) the trial court abused its discretion in issuing the injunction at issue, and the injunction was unenforceable. View "Kent Literary Club of Wesleyan University v. Wesleyan University" on Justia Law

In this dispute over who had the authority to lease shellfishing beds on behalf of the Town of Branford, the Supreme Court reversed the trial court's grant of summary judgment in favor of the Town, holding that summary judgment was improper.Plaintiffs had been granted the right of first refusal by Branford's Shellfish Commission to lease certain shellfishing grounds located in the Town, but the Commission leased the grounds to Plaintiffs' competitor. Plaintiff brought this action alleging breach of contract and promissory estoppel and that it enjoyed a right of first refusal. The Town moved for summary judgment, arguing that the right of first refusal was no a valid or enforceable contract because the Commission lacked authority to enter into it. The trial court agreed, holding that only the Town's Board of Selectmen had authority to lease the shellfishing beds on behalf of the Town. The Supreme Court reversed, holding that there was a genuine issue of material fact precluding summary judgment. View "Shoreline Shellfish, LLC v. Branford" on Justia Law

The Supreme Court reversed the conclusion of the trial court that Plaintiff, E. I. du Pont de Nemours & Co., had not strictly complied with the notice provisions of an asset purchase agreement (APA) and the court's judgment in favor of Defendant, Chemtura Corporation, holding that the trial court improperly required strict compliance with the APA's notice provisions.On appeal, Plaintiff argued that the trial court incorrectly concluded that New York law requires strict compliance with a notice provision in a commercial contract. Specifically, Plaintiff asserted that New York law distinguishes between public contracts and private commercial contracts and does not require strict compliance in commercial contracts if the contracting party receives actual notice and suffers from prejudice. The Court of Appeals agreed, holding that the trial court erred in requiring strict compliance with the APA's notice provision and in failing to make any other factual findings regarding Plaintiff's breach of contract claims. View "E. I. du Pont de Nemours & Co. v. Chemtura Corp." on Justia Law

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

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