section 52-190a certificate of good faith (Connecticut) · Go Syfert
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section 52-190a certificate of good faith in Connecticut

15 Connecticut opinions name it 3 courts 1994–2009 0 in the last five years

The cases below were cited by Connecticut courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (4)

CaseFollowedCited
LeConche v. Elligersyellow
conn · 1990 · cited in 2 Connecticut opinions naming this issue, 1999–2000
2 sentences

2000Raphael, 33 Conn. App. 378 , 384 , 635 A.2d 1232 , cert denied, 228 Conn. 928 , 640 A.2d 115 (1994); see also LeConche v. Elligers, supra, 215 Conn. 701 .

1999Raphael , 33 Conn. App. 378 , 384 , 635 A.2d 1232 , cert. denied, 228 Conn. 928 , 640 A.2d 115 (1994); see also LeConche v. Elligers , 215 Conn. 701 , 711 , 579 A.2d 1 (1990).

22
Gabrielle v. Hospital of St. Raphaelgreen
connappct · 1994 · cited in 11 Connecticut opinions naming this issue, 1995–2009
2 sentences

2009Raphael, 33 Conn. App. 378 , 635 A.2d 1232 , cert. denied, 228 Conn. 928 , 640 A.2d 115 (1994), for the proposition that the failure to include a good faith certificate under § 52-190a (a) was not a jurisdictional defect.

2009Raphael, 33 Conn. App. 378 , 635 A.2d 1232 , cert. denied, 228 Conn. 928 , 640 A.2d 115 (1994), for the proposition that the failure to include a good faith certificate under § 52-190a (a) was not a jurisdictional defect.

111
Camposano v. Claiborngreen
connappct · 1963 · cited in 1 Connecticut opinions naming this issue, 2002–2002
1 sentence

2002The Trimel court relied on language in Santopietro v. New Haven , 239 Conn. 207 , 226 (1996), which said: "Professional negligence or malpractice . . . is defined as the failure of one rendering professional services to exercise that degree of skill and learning commonly applied under all the circumstances in the community by the average prudent reputable member of the profession with the result of injury, loss or damage to the recipient of those services." Camposano v. Claiborn , 2 Conn. Cir. Ct. 135, 136-137 (1963), was also cited to the effect that malpractice "presupposes some improper con

11
Caron v. Adamsgreen
connappct · 1994 · cited in 1 Connecticut opinions naming this issue, 2001–2001
2 sentences

2001See Caron v. Adams, 33 Conn. App. 673, 690 , 638 A.2d 1073 (1994).

2001See Caron v. Adams, 33 Conn. App. 673, 690 , 638 A.2d 1073 (1994).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Connecticut. Read the followed side critically anyway.

Also cited on this issue (9)

CaseCitedYears
Gabrielle v. Hospital of St. Raphael neutral
conn · 1994
2 sentences

2009Raphael, 33 Conn. App. 378 , 635 A.2d 1232 , cert. denied, 228 Conn. 928 , 640 A.2d 115 (1994), for the proposition that the failure to include a good faith certificate under § 52-190a (a) was not a jurisdictional defect.

2009Raphael, 33 Conn. App. 378 , 635 A.2d 1232 , cert. denied, 228 Conn. 928 , 640 A.2d 115 (1994), for the proposition that the failure to include a good faith certificate under § 52-190a (a) was not a jurisdictional defect.

71999–2009
Interlude, Inc. v. Skurat green
conn · 2003
2 sentences

2004I do not think that the legislature, in enacting these two separate but closely related statutory provisions, intended such an irrational and bizarre result. 6 Instead, I think that we should interpret these provisions so that they form a coherent and rational, rather than an inconsistent and irrational, statutory scheme; Waterbury v. Washington, 260 Conn. 506, 557 , 800 A.2d 1102 (2002); so that they make sense when read together; Interlude, Inc. v. Skurat, 266 Conn. 130, 143-44 , 831 A.2d 235 (2003); and so that they carry out the closely related purposes of both, consistent with the limitat

2004I do not think that the legislature, in enacting these two separate but closely related statutory provisions, intended such an irrational and bizarre result. 6 Instead, I think that we should interpret these provisions so that they form a coherent and rational, rather than an inconsistent and irrational, statutory scheme; Waterbury v. Washington, 260 Conn. 506, 557 , 800 A.2d 1102 (2002); so that they make sense when read together; Interlude, Inc. v. Skurat, 266 Conn. 130, 143-44 , 831 A.2d 235 (2003); and so that they carry out the closely related purposes of both, consistent with the limitat

12004–2004
City of Waterbury v. Town of Washington green
conn · 2002
2 sentences

2004I do not think that the legislature, in enacting these two separate but closely related statutory provisions, intended such an irrational and bizarre result. 6 Instead, I think that we should interpret these provisions so that they form a coherent and rational, rather than an inconsistent and irrational, statutory scheme; Waterbury v. Washington, 260 Conn. 506, 557 , 800 A.2d 1102 (2002); so that they make sense when read together; Interlude, Inc. v. Skurat, 266 Conn. 130, 143-44 , 831 A.2d 235 (2003); and so that they carry out the closely related purposes of both, consistent with the limitat

2004I do not think that the legislature, in enacting these two separate but closely related statutory provisions, intended such an irrational and bizarre result. 6 Instead, I think that we should interpret these provisions so that they form a coherent and rational, rather than an inconsistent and irrational, statutory scheme; Waterbury v. Washington, 260 Conn. 506, 557 , 800 A.2d 1102 (2002); so that they make sense when read together; Interlude, Inc. v. Skurat, 266 Conn. 130, 143-44 , 831 A.2d 235 (2003); and so that they carry out the closely related purposes of both, consistent with the limitat

12004–2004
Hatt v. Burlington Coat Factory green
conn · 2003
2 sentences

2004I do not think that the legislature, in enacting these two separate but closely related statutory provisions, intended such an irrational and bizarre result. 6 Instead, I think that we should interpret these provisions so that they form a coherent and rational, rather than an inconsistent and irrational, statutory scheme; Waterbury v. Washington, 260 Conn. 506, 557 , 800 A.2d 1102 (2002); so that they make sense when read together; Interlude, Inc. v. Skurat, 266 Conn. 130, 143-44 , 831 A.2d 235 (2003); and so that they carry out the closely related purposes of both, consistent with the limitat

2004I do not think that the legislature, in enacting these two separate but closely related statutory provisions, intended such an irrational and bizarre result. 6 Instead, I think that we should interpret these provisions so that they form a coherent and rational, rather than an inconsistent and irrational, statutory scheme; Waterbury v. Washington, 260 Conn. 506, 557 , 800 A.2d 1102 (2002); so that they make sense when read together; Interlude, Inc. v. Skurat, 266 Conn. 130, 143-44 , 831 A.2d 235 (2003); and so that they carry out the closely related purposes of both, consistent with the limitat

12004–2004
Davis v. Margolis green
conn · 1990
2 sentences

2002Raphael , 33 Conn. App. 378 , 384 , 635 A.2d 1232 , cert. denied, 228 Conn. 928 , 640 A.2d 115 (1994). 3 "Malpractice is commonly defined as the failure of one rendering professional services to exercise that degree of skill and learning commonly applied under all the circumstances in the community by the average prudent reputable member of the profession with the result of injury, loss, or damage to the recipient of those services." (Internal quotation marks omitted.) Davis v. Margolis , 215 Conn. 408 , 415 , 576 A.2d 489 (1990).

2002Raphael , 33 Conn. App. 378 , 384 , 635 A.2d 1232 , cert. denied, 228 Conn. 928 , 640 A.2d 115 (1994). 3 "Malpractice is commonly defined as the failure of one rendering professional services to exercise that degree of skill and learning commonly applied under all the circumstances in the community by the average prudent reputable member of the profession with the result of injury, loss, or damage to the recipient of those services." (Internal quotation marks omitted.) Davis v. Margolis , 215 Conn. 408 , 415 , 576 A.2d 489 (1990).

12002–2002
Santopietro v. City of New Haven green
conn · 1996
1 sentence

2002The Trimel court relied on language in Santopietro v. New Haven , 239 Conn. 207 , 226 (1996), which said: "Professional negligence or malpractice . . . is defined as the failure of one rendering professional services to exercise that degree of skill and learning commonly applied under all the circumstances in the community by the average prudent reputable member of the profession with the result of injury, loss or damage to the recipient of those services." Camposano v. Claiborn , 2 Conn. Cir. Ct. 135, 136-137 (1963), was also cited to the effect that malpractice "presupposes some improper con

12002–2002
Trimel v. Lawrence & Memorial Hospital Rehabilitation Center green
connappct · 2001
1 sentence

2002If that is the case, a motion to strike should be sustained against the first two counts which allege a tort against a healthcare provider, a physician. 2 The defendant cites the case of Trimel v. Lawrence Memorial Hospital , 61 Conn. App. 353 (2001), which held that the plaintiffs negligence claim sounded in medical malpractice and thus required the filing of a good faith certificate under § 52-190a .

12002–2002
Barnes v. Schlein green
conn · 1984
2 sentences

1999Raphael, 33 Conn. App. 378 , 383-84 , 635 A.2d 1232 (1994) [W]hether [a] plaintiff's cause of action is one for malpractice depends upon the definition of that work and the allegations of the complaint." Barnes v. Schlein, 192 Conn. 732 , 735 , 473 A.2d 1221 (1984).

1999Raphael, 33 Conn. App. 378 , 383-84 , 635 A.2d 1232 (1994) [W]hether [a] plaintiff's cause of action is one for malpractice depends upon the definition of that work and the allegations of the complaint." Barnes v. Schlein, 192 Conn. 732 , 735 , 473 A.2d 1221 (1984).

11999–1999
Ecker v. Town of West Hartford green
conn · 1987
2 sentences

1994Statutes of limitations are statutes of repose and are designed to “(1) prevent the unexpected enforcement of stale and fraudulent claims by allowing persons after the lapse of a reasonable time, to plan their affairs with a reasonable degree of certainty, free from the disruptive burden of protracted and unknown potential liability, and (2) to aid in the search for truth that may be impaired by the loss of evidence, whether by death or disappearance of witnesses, fading memories, dis appearance of documents or otherwise.” Ecker v. West Hartford, 205 Conn. 219, 240 , 530 A.2d 1056 (1987); Wynn

1994Statutes of limitations are statutes of repose and are designed to “(1) prevent the unexpected enforcement of stale and fraudulent claims by allowing persons after the lapse of a reasonable time, to plan their affairs with a reasonable degree of certainty, free from the disruptive burden of protracted and unknown potential liability, and (2) to aid in the search for truth that may be impaired by the loss of evidence, whether by death or disappearance of witnesses, fading memories, dis appearance of documents or otherwise.” Ecker v. West Hartford, 205 Conn. 219, 240 , 530 A.2d 1056 (1987); Wynn

11994–1994

Statutes the citing opinions construe

CT § Conn. Gen. Stat. § 52-190a (15) CT § Conn. Gen. Stat. § 52-184c (5) CT § Conn. Gen. Stat. § 52-584 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

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