Justia Connecticut Supreme Court Opinion Summaries

The parties in this case were two specialty food business and their respective owners. The current dispute arose when the companies signed a distribution agreement and orally promised to form a joint venture between the businesses. After one company formally terminated the distribution agreement, Plaintiffs sued Defendants seeking to recover money damages for breach of an oral contract and promissory estoppel for failing to form the joint venture. The trial court found in favor of Defendants on all of Plaintiffs’ claims except promissory estoppel and rendered judgment for Defendants on their breach of contract counterclaim. Both parties appealed. The Supreme Court affirmed the judgment of the trial court in all respects, holding that the trial court properly (1) calculated Plaintiffs’ damages; (2) rendered judgment for Defendants on their counterclaim; and (3) rendered judgment for Plaintiffs on their promissory estoppel claim. View "Weiss v. Smulders" on Justia Law

Plaintiff contracted with the Town of Bethel to perform electrical work in connection with the Town’s renovation of its high school. Plaintiff later sued the Town, alleging breach of contract and unjust enrichment and claiming that the Town must reimburse it for additional costs incurred due to the Town’s ongoing asbestos abatement work at the school. The trial court rendered judgment for the Town in part, concluding that the Town's conduct did not fall within either of two judicial created exceptions to the enforcement of “no damages for delay” clauses adopted by the Court in White Oak Corp. v. Dep’t of Transportation. The Supreme Court affirmed the trial court’s decision that Plaintiff was not entitled to compensation under any of the “no damages for delay” exceptions at issue, holding (1) the term “active interference,” as used in the contract, did not require a showing of bad faith or gross negligence; but (2) the Town’s conduct in this case did not rise to the level of active interference or fall within either of the White Oak exceptions. View "C & H Elec., Inc. v. Town of Bethel" on Justia Law

Plaintiff brought a breach of contract action against Defendants. The trial court granted summary judgment in favor of Defendants, and the appellate court affirmed. Plaintiff appealed, arguing that the appellate court improperly upheld the trial court’s decision to grant Defendants’ motion for summary judgment on grounds not raised by Defendants. The Supreme Court affirmed, holding (1) a reviewing court has the discretion to raise and decide an issue that the parties themselves have not raised if (i) exceptional circumstances exist that would justify review of such an issue if raised by a party, (ii) the parties are given an opportunity to be heard on the issue, and (iii) no unfair prejudice to the party against whom the issue is to be decided results; (2) the appellate court in this case did not exceed its authority in resolving Plaintiff’s appeal on the basis of an issue that Defendants had not raised; and (3) the appellate court did not err in deciding the issue and in granting summary judgment to Defendants.View "Blumberg Assocs. Worldwide, Inc. v. Brown & Brown of Conn., Inc." on Justia Law

Defendant, the president of Moving America of CT, Inc., entered into a contract with Plaintiff, Yellow Book Sales and Distribution Company, Inc., on Moving America’s behalf. After Moving America dissolved, Plaintiff filed an action against Defendant in his individual capacity pursuant to an alleged individual guarantee in the contract, claiming that Defendant was individually liable to Plaintiff for the balance remaining unpaid on Moving America’s account. The trial court granted summary judgment in favor of Defendant, concluding that the contract was ambiguous as to whether Defendant was a party to the contract in his individual capacity, and therefore, the contract was unenforceable pursuant to the statute of frauds. The appellate court affirmed. The Supreme Court reversed, holding that the contract unambiguously identified Defendant as a party in his individual capacity and imposed a primary obligation, rather than a collateral one, on Defendant to provide full performance, thus rendering the statute of frauds inapplicable. Remanded. View "Yellow Book Sales & Distrib. Co., Inc. v. Valle" on Justia Law

Plaintiff and her employer (Defendant) signed a document regarding the terms of Plaintiff’s employment. The parties agreed the document would cover "a thirty-six month period." After Defendant terminated Plaintiff’s employment before the term expired, Plaintiff filed suit, alleging that she and Defendant had entered into a letter agreement for a fixed term of employment of thirty-six months and that Defendant violated the agreement. The trial court concluded that, on its face, the letter agreement constituted a contract for a definite term and that Defendant breached the agreement when it terminated Plaintiff’s employment without good cause before the term expired. The appellate court affirmed. The Supreme Court reversed, holding that the letter agreement was ambiguous. Specifically, the language of the letter agreement could reasonably be interpreted as evincing either an intent to create a definite term of employment or an intent to set the terms and conditions of an at-will employment contract, and therefore, the trial court should have considered extrinsic evidence to determine the intent of the parties. Remanded for a new trial. View "Cruz v. Visual Perceptions, LLC" on Justia Law

Plaintiff-school opened a bank account for its operating fund with Defendant-bank. One of Plaintiff’s employees later opened a bank account with Defendant that Plaintiff had not authorized and deposited into that account several hundred checks originating from, or intended to be deposited into, Plaintiff’s bank account with Defendant. Over the course of approximately four years, the employee deposited $832,776 into this bank account and withdrew funds just short of that amount. Defendant refused Plaintiff’s demand to return the funds that the employee had funneled through this account to himself. Thereafter, Plaintiff commenced this action, alleging breach of contract, violations of the Uniform Commercial Code (UCC), negligence, and common law conversion. The trial court rendered judgment in favor of Plaintiff on each of the counts and awarded $832,776 in total compensatory damages. The Supreme Court affirmed in all respects with the exception of the damages award, holding that some of Plaintiff’s claims under the UCC were time barred and that the trial court did not otherwise err in its judgment. Remanded with direction to reduce the award by $5,156 and to proportionately reduce prejudgment interest, . View "Saint Bernard Sch. of Montville, Inc. v. Bank of Am. " on Justia Law

In 2003, multiple residents of Greenwood Health Center, a nursing home, died or were injured when another resident set fire to the facility. Thirteen negligence actions seeking damages for wrongful death or serious bodily injury were filed against Greenwood, the lessee of the property housing Greenwood, the owner and lessor of the property, and the operator of Greenwood. Lexington Insurance Company (Plaintiff) brought this declaratory judgment action against the lessor of the Greenwood property, which was the insured party under a policy issued by Plaintiff, the other Greenwood entities, and the victims’ personal representatives. Following the filing of cross motions for summary judgment, the trial court determined the amount of coverage available under the policy and rendered judgment accordingly. Plaintiff appealed the judgment of the trial court determining available coverage, and four of the individual defendants cross appealed. The Supreme Court reversed in part, holding (1) the trial court improperly interpreted the endorsement relating to the aggregate policy limit, thereby providing more coverage for the individual defendants’ claims than that to which they were entitled; and (2) the trial court improperly applied the self-insured retention endorsement to reduce the available coverage. Remanded. View "Lexington Ins. Co. v. Lexington Healthcare Group, Inc." on Justia Law

In 2003, local districts established for the promotion of tourism were legislatively dissolved to make way for larger regional districts serving that same purpose. Plaintiff, a Massachusetts corporation, filed suit against one of the regional districts (Defendant) seeking to hold Defendant liable for damages under a contract that Plaintiff had executed with one of the local districts (Local District). The district court certified questions of law to the Supreme Court regarding the satisfaction of contingent liabilities of the legislatively dissolved local districts. The Supreme Court answered (1) Defendant is not the legal successor to the Local District, as the legislature did not intend to make the regional districts the legal successors to the local districts; and (2) if the Local District transferred any of its assets to another entity and Plaintiff can establish that the assets were fraudulently conveyed, that entity may be responsible for the Local District’s obligations to the extent of the value of the assets received. View "Single Source, Inc. v. Cent. Reg’l Tourism Dist., Inc." on Justia Law

Plaintiff filed a breach of contract action against Defendant, her insurer, claiming that Defendant improperly denied her claim for homeowners' insurance coverage after a fire damaged her home. BSI Financial Services, Inc., as the holder of the note and mortgage on Plaintiff's home, sought to intervene in the underlying action. The trial court denied the motion to intervene as untimely based on the policy's one year limitation period. The Supreme Court reversed, holding (1) the trial court erred in denying the motion to intervene without first determining whether the motion related back to the original complaint; and (2) the motion to intervene did not constitute a new, separate action but, rather, related back to Plaintiff's original complaint. Remanded.View "Austin-Cesares v. Safeco Ins. Co. of Am." on Justia Law

Plaintiff and Defendant entered into a series of agreements pursuant to which (1) Defendant agreed to transfer the management and, at the option of Plaintiff, the ownership of two automobile repair shops to Plaintiff; and (2) Plaintiff had the option to purchase the realty on which the shops were located on the condition that Plaintiff was in compliance with the terms of the agreements. When Plaintiff sought to exercise the options, Defendant refused to convey the properties, asserting that Plaintiff had not strictly complied with the agreements’ terms. The trial court determined that Plaintiff was entitled to specific performance of the options because it had substantially complied with the terms of the agreements. The Appellate Court reversed, concluding (1) the agreements were subject to a strict compliance standard, rather than a substantial compliance standard; and (2) Plaintiff had not strictly complied with the agreements' terms. The Supreme Court reversed, holding that the trial court (1) properly applied a standard of substantial rather than strict compliance with the terms of the parties’ agreements in resolving Plaintiffs’ claim; and (2) properly determined that Plaintiff was entitled to specific performance of the options because it had substantially complied with the terms of the parties’ agreements. View "Pack 2000, Inc. v. Cushman" on Justia Law