Justia Contracts Opinion Summaries

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.

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.

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.

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.

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.

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.

Plaintiff, American Diamond Exchange, brought an action against Defendant, Jurgita Karobikaite, and her husband, Scott Alpert, after Alpert, who was working as an estate buyer for Plaintiff, diverted Plaintiff's customers so that he could personally purchase their jewelry. Defendant shared in the profits. A judgment of default was entered against Alpert. The court found Defendant liable for tortious interference with a business relationship or expectancy and civil conspiracy and awarded Plaintiff $118,000 in damages. On appeal, the Appellate Court reversed the judgment of the trial court as to damages and remanded for a recalculation of damages based on the existing record. On remand, the trial court awarded $103,355 in damages to Plaintiff. Defendant appealed, claiming, inter alia, that Plaintiff failed to present sufficient evidence from which its lost profits could be determined with reasonable certainty. The Supreme Court reversed, holding (1) Defendant was not precluded from challenging the sufficiency of the evidence by failing to raise it in her direct appeal or because the appellate court decided the claim against her in the first appeal; and (2) the evidence was insufficient to support an award of damages.

Plaintiff, employee, brought an action against Defendants, an archdiocese and a parish pastor, claiming that their refusal to renew her contract for employment as the principal of the parish school constituted, inter alia, wrongful termination in violation of public policy, breach of implied contract and breach of promissory estoppel. The trial court denied Defendants' motion to dismiss the action on the ground that adjudication of Plaintiff's claims called for impermissible judicial interference in the internal governance of the archdiocese with respect to its selection of religious leaders. At issue on appeal was whether the ministerial exception to judicial authority that precludes a court from adjudicating certain religious disputes required dismissal of the action. The Supreme Court first determined it had subject matter jurisdiction over the interlocutory appeal, and then reversed the trial court, holding that (1) in considering whether the ministerial exception is applicable in a particular case, a Connecticut state court must follow the Rweyemamu v. Cote standard; and (2) the ministerial exception applied to the various claims in the plaintiff's complaint. Remanded with direction to dismiss Plaintiff's complaint.

Brady Dougan and Tomoko Dougan entered into a stipulation for judgment dissolving their marriage that contained a provision ordering Brady to pay interest if he failed to make payments to Tomoko. Both of the parties entered into the agreement with knowledge of its terms, and the trial court found the stipulation for judgment to be fair and reasonable. When Brady later failed to render a complete payment to defendant, Tomoko moved for enforcement of the stipulation and requested that the trial court order the plaintiff to pay her interest in accordance with the terms of the judgment. The trial court held that the provision for interest was invalid and unenforceable as against public policy. The appellate court reversed the judgment of the trial court. On Brady's appeal to the Supreme Court, Tomoko was granted special permission to raise the alternate ground that the judgment of the appellate court should be affirmed because the doctrine of judicial estoppel supports the enforcement of the interest provision. The Court agreed with Tomoko and affirmed the judgment of the appellate court, finding the doctrine of judicial estoppel barred Brady from claiming the provision was unenforceable.

Defendant and his wife appeal the trial court's judgment in a breach of contract and lien foreclosure action arising out of a dispute concerning the construction of a single-family home in the town of Greenwich. Defendants challenged all aspects of the trial court's judgment in favor of plaintiff except the portion of the judgment awarding plaintiff loss profit. Plaintiff challenged in his cross-appeal that the trial court improperly accepted the attorney trial referee's determination that the mechanic's lien was invalid and therefore improperly awarded defendants damages under General Statutes 49-8(c). The court held that because plaintiff and third party defendant offered no legal support for the attorney trial referee's finding that the wife was liable for breaching the contract between defendant and plaintiff, the portion of the trial court's judgment that was rendered against her could not stand. The court also held that the judgment of foreclosure must be reversed where there was no evidence that plaintiff furnished any materials or provided any services in connection with the contract balance and that the portion of the judgment awarding plaintiff attorney's fees pursuant to General Statutes 52-249 must also be reversed where such an award was authorized only when a valid judgment of foreclosure had been obtained. The court further held that the parties did not intend to impose liability for delays in the permitting and wetlands approval process and that the attorney trial referee improperly found that plaintiff was entitled to damages for the delays attributable to the change orders. The court also held that because plaintiff was not entitled to recover delay damages, it necessarily followed that any mechanic's lien securing those damages was invalid. The court finally held that the case must be remanded to the trial court for a determination of reasonable attorney's fees in accordance with section 49-8(c).