Justia Connecticut Supreme Court Opinion Summaries

This case arose from disputes between the Department of Information Technology and Defendant, a computer equipment supplier, over two contracts between the parties. The Department filed this action against Defendant, alleging breach of contract and fraud claims. Defendant filed an amended counterclaim, alleging takings and due process violations. The Department moved to dismiss the takings and due process claims based on the State's sovereign immunity. The trial court determined that the Department had waived the State's sovereign immunity regarding Defendant's counterclaims by bringing this cause of action against Defendant. After a jury trial, the trial court awarded Defendant damages on its procedural due process counterclaim. The Supreme Court (1) reversed the judgment of the trial court in favor of Defendant on the procedural due process counterclaim, holding that the Department did not waive the state's sovereign immunity by initiating the present litigation, and therefore, the trial court lacked subject matter jurisdiction over Defendant's counterclaims; and (2) affirmed in all other respects. View "Chief Info. Officer v. Computers Plus Ctr., Inc." on Justia Law

A construction company (Constructor) retained Defendant to arrange insurance for a new housing development. Defendant procured insurance from two insurance companies (Peerless and Hartford). Peerless denied coverage for a house destroyed by fire that was built on a lot not listed in Peerless's policy. Haynes claimed against Defendant for its negligent omission of the lot. Defendant gave notice of the loss to Plaintiff, from whom Defendant had purchased errors and omissions coverage. Defendant and Plaintiff settled with Constructor for $354,000. Constructor assigned its rights against Peerless and Hartford to Plaintiff and Defendant collectively. Defendant and Plaintiff then proceeded against the insurers for the $354,000. After the parties settled, $208,000 was deposited in an escrow account. Plaintiff sought a declaration that it was entitled to all of the escrow funds. Defendant counterclaimed for a declaration that, under Connecticut's make whole doctrine, it was entitled to recover the $150,000 deductible it contributed to the $354,000. The district court granted summary judgment for Plaintiff. The Supreme Court accepted certification from the appellate court and answered its questions by holding (1) the make whole doctrine is the default rule under Connecticut law; and (2) the make whole doctrine does not apply to insurance policy deductibles. View "Fireman's Fund Ins. Co. v. TD Banknorth Ins. Agency, Inc." on Justia Law

Plaintiff, a construction company, agreed by contract to perform site work for Hoffman Enterprises on several parcels of property. Plaintiff later filed this action against Hoffman Enterprises and Jeffrey Hoffman for negligent misrepresentation, among other claims. The trial court granted Hoffman's motion to strike the negligent misrepresentation claim. The appellate court reversed. Hoffman appealed, asserting that Plaintiff could not, as a matter of law, satisfy the detrimental reliance element of its claim because Hoffman's apparent authority to bind Hoffman Enterprises contractually meant that Plaintiff could not have relied to its detriment on Hoffman's statements. The Supreme Court affirmed, holding (1) the fact that allegations pleaded in a complaint might also state a contractual claim against a corporate entity under the apparent authority doctrine does not preclude a separate claim of negligent misrepresentation against a principal of that corporate entity as a matter of law; and (2) Plaintiff pleaded a legally sufficient claim of negligent misrepresentation. View "Coppola Constr. Co. v. Hoffman Enters. Ltd. P'ship" on Justia Law

In 2003, multiple residents of a nursing home (Greenwood) died or were injured when another resident set fire to the facility. Consequently, thirteen negligence actions seeking damages for serious bodily injury or wrongful death were filed against Greenwood, the owner of the property housing Greenwood, the lessee of the property (Lexington Healthcare), and the operator of Greenwood. Plaintiff issued a general liability and professional liability insurance policy to Lexington Healthcare. At issue in this case was the amount of liability insurance coverage available for the claims. The trial court determined the amount available under the policy and rendered judgment accordingly. The Supreme Court reversed in part, holding (1) the trial court improperly interpreted a policy endorsement in the policy relating to the aggregate policy limit; and (2) the trial court improperly applied a self-insured retention endorsement to reduce the available coverage. Remanded. View "Lexington Ins. Co. v. Lexington Healthcare Group, Inc." on Justia Law

Wyatt Energy unilaterally terminated an agreement with Motiva Enterprises granting Motiva exclusive use of logistical and storage services provided by a gasoline distribution terminal owned by Wyatt after Motiva purchased a competing terminal owned by Cargill. Wyatt subsequently sold its terminal to Williams Energy without requiring Williams to assume Wyatt's obligations under the agreement with Motiva. Wyatt then brought this breach of contract action against Motiva. Motiva counterclaimed for breach of contract. Wyatt asserted a special defense of illegality premised on purported antitrust violations arising out of Motiva's purchase of the Cargill terminal. The trial court held in favor of Motiva, and the appellate court affirmed. The Supreme Court dismissed Wyatt's appeal, holding that Wyatt's claim that the trial court incorrectly defined the relevant product and geographic markets was moot because, even if Wyatt's proposed market definitions were assumed to be correct, Wyatt could not be afforded any practical relief. View "Wyatt Energy, Inc. v. Motiva Enters., LLC" on Justia Law

Defendant contracted with Plaintiffs to purchase their oil recycling business. The parties carried out the purchase using three contracts. All but one of these contracts, the equipment contract, contained provisions entitling Defendant to attorney's fees in the event Plaintiffs breached the agreements. Plaintiffs later commenced this action seeking damages for Defendant's alleged breach of the contracts and for unjust enrichment. Defendant counterclaimed for breach of contract. The jury found in favor of Defendants on their counterclaim but awarded damages only with respect to Plaintiffs' breach of the equipment contract. The trial court denied Defendant's motion for attorney's fees. The appellate court reversed with respect to attorney's fees. On remand, the trial court denied Defendant's motion for attorney's fees. The appellate court affirmed. The Supreme Court reversed, holding (1) the trial court improperly applied the law of the case doctrine under these circumstances and improperly rejected Defendant's motion for attorney's fees without reaching the merits of that claim; and (2) when certain claims provide for a party's recovery of contractual attorney's fees but others do not, a party is nevertheless entitled to reasonable attorneys fees if an apportionment is impracticable because the claims arise from a common factual nucleus and are intertwined. Remanded. View "Total Recycling Servs. of Conn., Inc. v. Conn. Oil Recycling Servs., LLC" on Justia Law

Plaintiff was an additional insured on a commercial general liability insurance policy, which was issued to Plaintiff's tenant (Tenant) by Defendant, Travelers Property Casualty Company (Travelers). Plaintiff sought to invoke Travelers' duty to defend under the policy after Sarah Middeleer was injured in a fall on Plaintiff's property and brought the underlying action against Plaintiff. Plaintiff's insurer, the Netherlands Insurance Company (Netherlands), provided a defense to Plaintiff after Travelers denied any duty to defend Plaintiff in the underlying action. Plaintiff then brought the present action claiming Travelers had a duty to defend Plaintiff in the underlying action and Travelers was obligated to reimburse Netherlands for the defense costs it had expended. The trial court granted Plaintiff's motion for summary judgment. The appellate court reversed, concluding that Middeleer's injuries did not arise out of the use of the leased premises under the terms of the policy. The Supreme Court affirmed, holding that the appellate court correctly construed the governing policy language and properly concluded that Travelers did not have a duty to defend Plaintiff. View "Misiti, LLC v. Travelers Prop. Cas. Co. of Am." on Justia Law

Plaintiff and her husband were traveling in Plaintiff's automobile when Tortfeasor collided with the automobile, causing significant injuries to Plaintiff and her husband. At the time of the collision, the motor vehicle driven by Tortfeasor was underinsured. Plaintiff submitted a claim for underinsured motorist coverage to her Insurer. Insurer refused to provide coverage in light of Plaintiff's recovery under a settlement agreement with Tortfeasor. Subsequently, Plaintiff brought this action seeking underinsured motorist coverage under her policy. The trial court granted summary judgment for Insurer, concluding Insurer was entitled to a setoff equal to the amount of the entire settlement. The Supreme Court affirmed, holding that Insurer was entitled to a reduction of its limits of liability for underinsured motorist coverage by an amount equal to the sum of punitive damages paid to Plaintiff. View "Anastasia v. Gen. Cas. Co. of Wis." on Justia Law

Plaintiffs filed this action against Defendants seeking a declaratory judgment that, under the doctrine of adverse possession, Plaintiffs were the owners of a parcel of land bordering Defendants' property. The parties reached a settlement agreement providing for a new boundary line between their properties. The agreement provided that Defendants would apply for and pursue a variance from the town zoning board of appeals because the new boundary line left Defendants with slightly less than the minimum frontage requirement. Plaintiffs later filed a motion to enforce the settlement agreement, which the trial court granted. The trial court ultimately conveyed the property to Plaintiffs. The appellate court reversed in part and remanded to the trial court with direction to render a judgment of adverse possession in favor of Plaintiffs contingent on the parties' compliance with the terms of the settlement agreement. The Supreme Court granted Defendants' petition for certification to appeal. However, after examining the record, the Court dismissed the appeal on the ground that certification was improvidently granted. View "Vance v. Tassmer" on Justia Law

Defendant's father was a resident at Plaintiff's nursing care facility until his death. After Defendant refused to pay Plaintiff the outstanding bill from her father's assets, Plaintiff filed this action against Defendant, claiming breach of contract and fraud. The trial court held in favor of Defendant, concluding that Defendant did not have a power of attorney for her father and did not have access to his checking account or to any of his other financial resources. The court also awarded attorney's fees to Defendant under Conn. Gen. Stat. 42-150bb for successfully defending against a commercial party's action based on a contract. The appellate court reversed in part, concluding that Defendant was not entitled to attorney's fees under section 42-150bb because she was not the personal representative of her father. The Supreme Court reversed in part, holding that the appellate court improperly concluded that, in order to be a "personal representative" entitled to fees under section 42-150bb, Defendant would have to be a legal representative of the party to the contract. Remanded. View "Aaron Manor, Inc. v. Irving" on Justia Law