Justia Connecticut Supreme Court Opinion Summaries

The Supreme Court reversed the judgment of the trial court in favor of Defendant on Plaintiff’s complaint and Defendant’s counterclaim for damages and declaratory judgment. This case stemmed from a purchase agreement entered into by the parties in which Plaintiff was to provide various equipment and services to Defendant for a telecommunications switch room. The Supreme Court held (1) the trial court incorrectly concluded that Plaintiff breached the purchase agreement by filing a petition for bankruptcy protection under chapter 11 of the United States Bankruptcy Code; and (2) the trial court erred in determining that Defendant was within its rights to terminate the purchase agreement upon Plaintiff’s initiation of bankruptcy proceedings. View "CCT Communications, Inc. v. Zone Telecom, Inc." on Justia Law

The Supreme Court reversed in part the judgment of the Appellate Court, which reversed the judgment of the trial court in favor of Defendant on both Plaintiff’s complaint seeking recovery on six promissory notes and on Defendant’s counterclaim alleging a violation of the Connecticut Unfair Trade Practices Act (CUTPA). On appeal, Plaintiff challenged only the scope of the Appellate Court’s remand order, arguing that the court erred in ordering a new trial rather than restricting the remand proceedings to a hearing in damages. The Supreme Court reversed the judgment of the Appellate Court in part, holding that a new trial was unnecessary because Defendant lacked standing to pursue a claim alleging a violation of CUTPA. View "Channing Real Estate, LLC v. Gates" on Justia Law

Defendant was charged with larceny in the third degree as an accessory and conspiracy to commit larceny in the third degree. Defendant moved to dismiss the charges on the basis of the State’s prior entry of a nolle prosequi on the same charges. The trial court denied the motion to dismiss. The appellate court reversed on the ground that the entry of a nolle on those charges and nolles on charges in three other cases was part of an agreement between the State and Defendant contemplating a global disposition supported by consideration. Therefore, the appellate court concluded that Defendant’s prosecution in the present proceeding was barred. The Supreme Court affirmed, holding that the agreement was ambiguous as to the parties’ intent and therefore must be construed in Defendant’s favor as a global disposition. View "State v. Kallberg" on Justia Law

Plaintiff were a class of state employees and retirees who were enrolled in an Anthem Insurance group health insurance plan at the time of the 2001 demutualization of Anthem Insurance Companies. Plaintiffs brought suit against former Governor John Rowland, the State, Anthem Insurance, and other insurance company defendants alleging that their participation in the plan entitled them to membership in Anthem Insurance and a share of the demutualization proceeds. Plaintiffs claimed that Anthem Insurance and the other insurance company defendants breached their contractual obligations by not paying Plaintiffs for their membership interests and instead distributing their share of the proceeds to the State. The Supreme Court concluded that Plaintiffs’ claims against Rowland and the State were barred by the doctrine of sovereign immunity or otherwise should have been dismissed. After a trial, the trial court rendered judgment for the remaining defendants. The Supreme Court affirmed, holding that the trial court correctly concluded that the relevant contract provisions were ambiguous as to Plaintiffs’ eligibility for membership in Anthem Insurance and their entitlement to a share of the demutualization proceeds and properly considered extrinsic evidence to determine their meaning. View "Gold v. Rowland" on Justia Law

Contractor and Homeowner entered into an agreement whereby Contractor agreed to furnish materials and supply labor in connection with renovations to Homeowner’s residence. After the renovation project was largely complete, the parties began to dispute the amounts that Homeowner owed Contractor. Contractor then brought this action claiming, inter alia, breach of contract and unjust enrichment. Homeowner raised the special defense that Contractor’s claims were barred because the agreement did not comply with the Home Improvement Act. In response, Contractor argued that Homeowner was precluded from relying on the Act because his refusal to pay Contractor was in bad faith. The trial court agreed with Contractor and rendered judgment for Contractor. The Appellate Court affirmed. The Supreme Court reversed, holding that Homeowner did not act in bad faith, and therefore, the trial court improperly found that Homeowner was barred from invoking the protection of the Act. Remanded with direction to render judgment for Homeowner. View "Burns v. Adler" on Justia Law

Defendant was an attorney who represented clients in contingency fee matters that originated while he was a member of a two-person law firm with Plaintiff. After the dissolution of that firm, Defendant continued to represent those clients, and those fees were not paid until after the dissolution. Plaintiff brought this action claiming that Defendant’s failure to pay him those fees constituted, inter alia, breach of contract and unjust enrichment. The trial court concluded that Plaintiff was entitled to recover on his claim of unjust enrichment with respect to the contingency fee cases and found that Defendant owed Plaintiff $116,298.89. Defendant appealed, arguing that the award violated the fee splitting provisions of Rule 1.5(e) of the Rules of Professional Conduct because the clients had not consented to the fee sharing. The Supreme Court affirmed, holding that the trial court properly awarded Plaintiff a portion of the contingency fees that Defendant collected subsequent to the firm’s dissolution. View "Horner v. Bagnell" on Justia Law

Plaintiff entered into a purchase agreement providing that Plaintiff was to provide various telecommunications equipment, software, and services to Defendant for a switch room located in Los Angeles. Defendant later terminated the purchase agreement. Plaintiff filed a complaint claiming breach of contract for Defendant’s failure to pay the amounts owed and account stated. Defendant counterclaimed for, inter alia, breach of contract for Plaintiff’s failure to provide services under the purchase agreement. The trial court entered judgment for Defendant on the complaint and the breach of contract count of the counterclaim. The court later articulated that Plaintiff had breached the purchase agreement. The Supreme Court affirmed, holding that the trial court (1) did not err in concluding that Plaintiff breached the purchase agreement; (2) did not err in finding that Plaintiff failed to prove its breach of contract claim; and (3) properly awarded damages, cost and attorney’s fees in light of a limitation of liability clause in the purchase agreement. View "CCT Communications, Inc. v. Zone Telecom, Inc." on Justia Law

Defendant Gary Proctor set up an account of electric services for a new business. After Defendant contacted Plaintiff, Connecticut Light and Power Company, Plaintiff provided electric service to the business under an account in Defendant’s name until it disconnected service for non-payment. Plaintiff then brought an action against Defendant for breach of an implied contract and unjust enrichment seeking $14,620 in outstanding bills. The trial court rendered judgment for Plaintiff on the breach of an implied contract count, finding that Defendant manifested assent to enter into an implied in fact contract with Plaintiff under which Defendant would be responsible for payment for the provision of electric services to the company. The Appellate Court affirmed. The Supreme Court affirmed, holding that there was sufficient evidence to support the trial court’s finding that Defendant entered into an implied in fact contract with Plaintiff. View "Connecticut Light & Power Co. v. Proctor" on Justia Law

At issue in this case was whether, under Connecticut law, after a judgment debtor’s wages have been garnished, the remaining wages are exempt from execution, and whether the transfer of those wages to a third party constitutes a fraudulent transfer. Pursuant to two state court judgments, The Cadle Company was Terry Fletcher’s judgment creditor, Fletcher owing the company more than $3 million. Since at least 2005, Terry has transferred more than $300,000 of his residual wages to the bank account of his wife, Marguerite Fletcher. The Cadle Company sued the Fletchers in federal district court, alleging, inter alia, that the transfer violated the Connecticut Uniform Fraudulent Transfer Act (CUFTA). The district court granted the Fletchers’ motion for partial summary judgment, granted The Cadle Company’s motion for partial summary judgment, and ultimately rendered judgment for The Cadle Company in the amount of $401,426 on its CUFTA claim. The Fletchers appealed to the Second Circuit Court of Appeals. The Second Circuit subsequently certified a question to the Supreme Court, which the Court accepted. The Supreme Court answered that Terry’s residual wages would not have been exempt from execution if he had retained possession of them, and therefore, they were subject to execution after Terry transferred them to his wife’s account. View "Cadle Co. v. Fletcher" on Justia Law

After hiring Plaintiff, Defendant-employer amended its sales commission plan. At dispute in this case was a revised commission provision, which provided that Plaintiff’s commissions would not be paid unless Defendant had invoiced commissionable amount to the client prior to Plaintiff’s termination. After Plaintiff was terminated, he filed a wage statute claim alleging that the commission provision was contrary to public policy and a violation of Conn. Gen. Stat. 31-72. Plaintiff’s remaining two claims were stricken upon Defendant’s motion. After a trial, the court granted judgment in favor of Plaintiff, holding that the commission provision at issue was contrary to public policy. Both parties appealed. The Supreme Court affirmed in part and reversed in part, holding that the trial court (1) improperly determined that the commission provision violated public policy and constituted a violation of section 31-72; (2) erred in striking Plaintiff’s claim alleging breach of the implied covenant of good faith and fair dealing; and (3) did not err in striking Plaintiff’s claim alleging wrongful discharge. Remanded. View "Geysen v. Securitas Security Servs. USA, Inc." on Justia Law