continuing violation (Connecticut) · Go Syfert
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continuing violation in Connecticut

24 Connecticut opinions name it 3 courts 1987–2024 4 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 (24)

CaseFollowedCited
State v. Commission on Human Rights & Opportunitiesgreen
conn · 1989 · cited in 4 Connecticut opinions naming this issue, 1999–2021
2 sentences

2018See Knight v. Columbus, supra, 19 F.3d at 581 ("[w]here a continuing violation is found, the plaintiffs can recover for any violations for which the statute of limitations has not expired"); see also State v. Commission on Human Rights & Opportunities , supra, 211 Conn. at 472 -73 , 559 A.2d 1120 .

2018See Knight v. Columbus, supra, 19 F.3d at 581 ("[w]here a continuing violation is found, the plaintiffs can recover for any violations for which the statute of limitations has not expired"); see also State v. Commission on Human Rights & Opportunities , supra, 211 Conn. at 472 -73 , 559 A.2d 1120 .

24
Commissioner of Environmental Protection v. Connecticut Building Wrecking Co.green
conn · 1993 · cited in 2 Connecticut opinions naming this issue, 2024–2024
2 sentences

2024See Commissioner of Environmental Protection v. Con- necticut Building Wrecking Co., 227 Conn. 175 , 197–99, 629 A.2d 1116 (1993) (defendants’ ongoing failure to remove solid waste that they had illegally dumped in protected wetland qualified as continuing violation of General Statutes § 22a-32).

2024See Commissioner of Environmental Protection v. Con- necticut Building Wrecking Co., 227 Conn. 175 , 197–99, 629 A.2d 1116 (1993) (defendants’ ongoing failure to remove solid waste that they had illegally dumped in protected wetland qualified as continuing violation of General Statutes § 22a-32).

22
Alphonse BOGE, Jr., Appellant, v. RINGLAND-JOHNSON-CROWLEY COMPANY, Appelleegreen
ca8 · 1992 · cited in 2 Connecticut opinions naming this issue, 2006–2024
2 sentences

2024Appx. 701, 704 (10th Cir. 2012) (concluding that ‘‘[the defendant’s] alleged retaliatory failure to rehire [the plaintiff] was a discrete act’’); Boge v. Ringland-Johnson-Crowley Co., 976 F.2d 448, 451 (8th Cir. 1992) (‘‘[A]n employer’s fail- ure to recall or rehire does not constitute a continuing violation . . . .

2006Each incident of discrimination and each retaliatory adverse employment decision constitutes a separate actionable unlawful employment practice.” [Internal quotation marks omitted.]); Boge v. Ringland-Johnson-Crowley Co., 976 F.2d 448, 451 (8th Cir. 1992) (“[A]n employer’s failure to recall or rehire does not constitute a continuing violation of the [Age Discrimination in Employment Act, 29 U.S.C. § 621 et seq.].

22
Peter L. Knight, Dennis L. Wall, Michael D. Mulkey v. Columbus, Georgiagreen
ca11 · 1994 · cited in 2 Connecticut opinions naming this issue, 2018–2021
2 sentences

2021See Knight v. Colum- bus, [ 19 F.3d 579, 581 (11th Cir.)] (‘[w]here a continuing violation is found, the [plaintiff] can recover for any violations for which the statute of limitations has not expired’) [cert. denied, 513 U.S. 929 , 115 S. Ct. 318 , 130 L.

2018"The critical distinction in the continuing violation analysis ... is whether the plaintiffs complain of the present consequence of a one time violation, which does not extend the limitations period, [or] the continuation of that violation into the present, which does." (Internal quotation marks omitted.) Knight v. Columbus, 19 F.3d 579 , 580-81 (11th Cir.), cert. denied, 513 U.S. 929 , 115 S.Ct. 318 , 130 L.Ed. 2d 280 (1994).

22
Scheib v. Grantgreen
scotus · 1994 · cited in 2 Connecticut opinions naming this issue, 2018–2021
2 sentences

2021See Knight v. Colum- bus, [ 19 F.3d 579, 581 (11th Cir.)] (‘[w]here a continuing violation is found, the [plaintiff] can recover for any violations for which the statute of limitations has not expired’) [cert. denied, 513 U.S. 929 , 115 S. Ct. 318 , 130 L.

2018"The critical distinction in the continuing violation analysis ... is whether the plaintiffs complain of the present consequence of a one time violation, which does not extend the limitations period, [or] the continuation of that violation into the present, which does." (Internal quotation marks omitted.) Knight v. Columbus, 19 F.3d 579 , 580-81 (11th Cir.), cert. denied, 513 U.S. 929 , 115 S.Ct. 318 , 130 L.Ed. 2d 280 (1994).

12
Murph v. Lincoln Reserve Life Insurancegreen
sc · 1921 · cited in 2 Connecticut opinions naming this issue, 2018–2021
2 sentences

2021See Knight v. Colum- bus, [ 19 F.3d 579, 581 (11th Cir.)] (‘[w]here a continuing violation is found, the [plaintiff] can recover for any violations for which the statute of limitations has not expired’) [cert. denied, 513 U.S. 929 , 115 S. Ct. 318 , 130 L.

2018"The critical distinction in the continuing violation analysis ... is whether the plaintiffs complain of the present consequence of a one time violation, which does not extend the limitations period, [or] the continuation of that violation into the present, which does." (Internal quotation marks omitted.) Knight v. Columbus, 19 F.3d 579 , 580-81 (11th Cir.), cert. denied, 513 U.S. 929 , 115 S.Ct. 318 , 130 L.Ed. 2d 280 (1994).

12
Conservation Commission v. Pricegreen
conn · 1984 · cited in 2 Connecticut opinions naming this issue, 1991–2010
2 sentences

2010General Statutes § 22a-44 (b) provides in relevant part: “The Superior Court, in an action brought by the commissioner, municipality, district or any person, shall have jurisdiction to restrain a continuing violation of said sections, to issue orders directing that the violation be corrected or removed and to assess civil penalties pursuant to this section. . . .’’In our jurisprudence, this distinction is significant. “[W]here a statute authorizes a municipality or public entity to seek an injunction in order to enforce compliance with a local zoning ordinance, but says nothing about the injur

2010General Statutes § 22a-44 (b) provides in relevant part: “The Superior Court, in an action brought by the commissioner, municipality, district or any person, shall have jurisdiction to restrain a continuing violation of said sections, to issue orders directing that the violation be corrected or removed and to assess civil penalties pursuant to this section. . . .’’In our jurisprudence, this distinction is significant. “[W]here a statute authorizes a municipality or public entity to seek an injunction in order to enforce compliance with a local zoning ordinance, but says nothing about the injur

12
Subhash C. MALHOTRA, Plaintiff-Appellant, v. COTTER & COMPANY, Defendant-Appelleegreen
ca7 · 1989 · cited in 2 Connecticut opinions naming this issue, 1999–1999
2 sentences

1999Malhotra v. Coffer Co. , 885 F.2d 1305 (7 th Cir. 1989).

1999The court stated that: "[N]o part of a continuing violation which persists into the period within which suit is allowed is time-barred." (Emphasis in original.) Id., 1310 .

12
Dr. Julia Elizabeth Berry v. The Board of Supervisors of L.S.U., Etc.green
ca5 · 1983 · cited in 1 Connecticut opinions naming this issue, 2024–2024
2 sentences

2024Each alleged discriminatory recall constitutes a separate and completed act by the defen- dant, which triggers a new [statutory limitation] period.’’ (Internal quotation marks omitted.)); Berry v. Board of Supervisors of L.S.U., 715 F.2d 971, 980 (5th Cir. 1983) (defendant’s ‘‘failure to rehire was a discrete act which was not part of a continuing violation’’); Ever- ett v. 357 Corp., 453 Mass. 585 , 606–607, 904 N.E.2d 733 (2009) (‘‘the failure to rehire an employee is consid- ered a discrete, separate act that does not draw other allegedly discriminatory acts into its scope’’).

2024Each alleged discriminatory recall constitutes a separate and completed act by the defen- dant, which triggers a new [statutory limitation] period.’’ (Internal quotation marks omitted.)); Berry v. Board of Supervisors of L.S.U., 715 F.2d 971, 980 (5th Cir. 1983) (defendant’s ‘‘failure to rehire was a discrete act which was not part of a continuing violation’’); Ever- ett v. 357 Corp., 453 Mass. 585 , 606–607, 904 N.E.2d 733 (2009) (‘‘the failure to rehire an employee is consid- ered a discrete, separate act that does not draw other allegedly discriminatory acts into its scope’’).

11
Morris v. Cabela's Wholesale, Inc.green
ca10 · 2012 · cited in 1 Connecticut opinions naming this issue, 2024–2024
1 sentence

2024Each alleged discriminatory [act] constitutes a separate and completed act by the defendant.’’ (Internal quotation marks omitted.) Jackson v. Water Pollution Control Authority, supra, 278 Conn. 706 n.12 ; see also Morris v. Cabela’s Wholesale, Inc., 486 Fed.

11
Delbert Heard v. Michael F. Sheahangreen
ca7 · 2001 · cited in 1 Connecticut opinions naming this issue, 2021–2021
1 sentence

2021In reality, that statement is a quotation attributable to the Seventh Circuit’s decision in Heard v. Sheahan, 253 F.3d 316, 320 (7th Cir. 2001), which, in turn, was citing the Eleventh Circuit decision of Knight v. Columbus, [supra, 19 F.3d 581–82], discussing whether the ‘continuing violation theory’ was applicable to a violation of the Fair Labor Standards Act. [ 29 U.S.C. § 201 et seq.] Importantly, the ‘continuing violation theory’ is not the same as the ‘continuing course of conduct doctrine.’ ’’ (Citation omitted.) The plaintiff is correct that these two cases discuss ‘‘continuing violat

11
Green v. Obledogreen
cal · 1981 · cited in 1 Connecticut opinions naming this issue, 2018–2018
2 sentences

2018See, e.g., Green v. Obledo , 29 Cal. 3d 126 , 141, 624 P.2d 256 , 172 Cal.Rptr. 206 (1981) ; Bishop v .

2018See, e.g., Green v. Obledo , 29 Cal. 3d 126 , 141, 624 P.2d 256 , 172 Cal.Rptr. 206 (1981) ; Bishop v .

11
Scott v. City of Sioux Citygreen
iowa · 1988 · cited in 1 Connecticut opinions naming this issue, 2017–2017
1 sentence

2017Wis. 2010) ("the adoption of an ordinance has immediate economic consequences for a land owner; the time for challenging it was within the state period of limitations"), aff'd, 631 F.3d 421 (7th Cir. 2011) ; see also Wellswood Columbia, LLC v. Hebron , supra, United States District Court, Docket No. 3:10-CV-1467 (VLB) (plaintiffs "suffered the continued ill effects of the single act of closing Wellswood Road" rather than continuing unlawful acts necessary to demonstrate **79 a continuing violation); Scott v. Sioux City , supra, 432 N.W.2d at 148 ("[T]he cause of action arises out of the enactm

11
Bettendorf v. St. Croix Countygreen
wiwd · 2010 · cited in 1 Connecticut opinions naming this issue, 2017–2017
1 sentence

2017Croix , 679 F.Supp.2d 974 , 978 (W.D.

11
Bradford Novelty Co. v. Technomatic, Inc.green
conn · 1955 · cited in 1 Connecticut opinions naming this issue, 2015–2015
2 sentences

2015Rather, for a course of performance to give rise to a continuing waiver, there must be ‘‘repeated occasions for performance and [the] opportunity for objection . . . .’’ (Emphasis omitted; internal quota- tion marks omitted.) Dallas Aerospace, Inc. v. CIS Air Corp., supra, 783; see, e.g., Bradford Novelty Co. v. Technomatic, Inc., 142 Conn. 166 , 170–71, 112 A.2d 214 (1955) (by repeatedly acquiescing in previous delays, obligee waived its right to insist on strict compliance with contractual provisions as to time of performance); Remington Arms Union Metallic Cartridge Co. v. Gaynor Mfg.

2015Rather, for a course of performance to give rise to a continuing waiver, there must be ‘‘repeated occasions for performance and [the] opportunity for objection . . . .’’ (Emphasis omitted; internal quota- tion marks omitted.) Dallas Aerospace, Inc. v. CIS Air Corp., supra, 783; see, e.g., Bradford Novelty Co. v. Technomatic, Inc., 142 Conn. 166 , 170–71, 112 A.2d 214 (1955) (by repeatedly acquiescing in previous delays, obligee waived its right to insist on strict compliance with contractual provisions as to time of performance); Remington Arms Union Metallic Cartridge Co. v. Gaynor Mfg.

11
Cornwell v. Robinsongreen
ca2 · 1994 · cited in 1 Connecticut opinions naming this issue, 2000–2000
11
Dowe v. Egangreen
conn · 1946 · cited in 1 Connecticut opinions naming this issue, 1995–1995
11
State v. Staubgreen
· 1892 · cited in 1 Connecticut opinions naming this issue, 1995–1995
11
Mario v. Town of Fairfieldgreen
conn · 1991 · cited in 1 Connecticut opinions naming this issue, 1993–1993
11
Rose v. Freedom of Information Commissiongreen
conn · 1992 · cited in 1 Connecticut opinions naming this issue, 1993–1993
11
Detroit Coil Company v. International Association of MacHinists & Aerospace Workers, Lodge 82green
ca6 · 1979 · cited in 1 Connecticut opinions naming this issue, 1987–1987
11
Perez v. Rodriguez de Quiñonezgreen
scotus · 1979 · cited in 1 Connecticut opinions naming this issue, 1987–1987
11
Lemelson v. Centsable Products, Inc.green
scotus · 1979 · cited in 1 Connecticut opinions naming this issue, 1987–1987
11
Brighton Building & Maintenance Co. v. United Statesgreen
scotus · 1979 · cited in 1 Connecticut opinions naming this issue, 1987–1987
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 (28)

CaseCitedYears
Board of Education v. Commission on Human Rights & Opportunities green
conn · 1979
2 sentences

1999Our Supreme Court recognized the continuing violation doctrine in Board of Education v. CHRO , 177 Conn. 75 , 411 A.2d 40 (1979), in holding that "discrete incidents occurring during a continuum of discriminatory employment practices may constitute fresh violations of [the] General Statutes." State v. CHRO , 211 Conn. 464 , 473 , 559 A.2d 1120 (1989).

1999The continuing violation doctrine was first recognized by the Connecticut Supreme Court in Board of Education v. Commission on Human Rights Opportunities , 177 Conn. 75 (1979).

31989–1999
Everett v. 357 Corp. green
mass · 2009
2 sentences

2024Each alleged discriminatory recall constitutes a separate and completed act by the defen- dant, which triggers a new [statutory limitation] period.’’ (Internal quotation marks omitted.)); Berry v. Board of Supervisors of L.S.U., 715 F.2d 971, 980 (5th Cir. 1983) (defendant’s ‘‘failure to rehire was a discrete act which was not part of a continuing violation’’); Ever- ett v. 357 Corp., 453 Mass. 585 , 606–607, 904 N.E.2d 733 (2009) (‘‘the failure to rehire an employee is consid- ered a discrete, separate act that does not draw other allegedly discriminatory acts into its scope’’).

2024Each alleged discriminatory recall constitutes a separate and completed act by the defen- dant, which triggers a new [statutory limitation] period.’’ (Internal quotation marks omitted.)); Berry v. Board of Supervisors of L.S.U., 715 F.2d 971, 980 (5th Cir. 1983) (defendant’s ‘‘failure to rehire was a discrete act which was not part of a continuing violation’’); Ever- ett v. 357 Corp., 453 Mass. 585 , 606–607, 904 N.E.2d 733 (2009) (‘‘the failure to rehire an employee is consid- ered a discrete, separate act that does not draw other allegedly discriminatory acts into its scope’’).

12024–2024
Giulietti v. Giulietti green
connappct · 2001
1 sentence

2021This means that each failure could easily be seen as its own breach with its own limitation period running from the point at which an installment of money was realized under the license.’’ The court then engaged in a discussion of both continu- ing violation analysis and the continuing course of con- duct doctrine, referring to them interchangeably,19 cit- ing both Giulietti v. Giulietti, supra, 65 Conn. App. 813 , a case concerning the continuing course of conduct doctrine, and Bouchard v. State Employees Retirement Commission, supra, 328 Conn. 345 , a case predomi- nantly addressing a contin

12021–2021
Bouchard v. State Emps. Ret. Comm'n green
conn · 2018
2 sentences

2021This means that each failure could easily be seen as its own breach with its own limitation period running from the point at which an installment of money was realized under the license.’’ The court then engaged in a discussion of both continu- ing violation analysis and the continuing course of con- duct doctrine, referring to them interchangeably,19 cit- ing both Giulietti v. Giulietti, supra, 65 Conn. App. 813 , a case concerning the continuing course of conduct doctrine, and Bouchard v. State Employees Retirement Commission, supra, 328 Conn. 345 , a case predomi- nantly addressing a contin

2021This means that each failure could easily be seen as its own breach with its own limitation period running from the point at which an installment of money was realized under the license.’’ The court then engaged in a discussion of both continu- ing violation analysis and the continuing course of con- duct doctrine, referring to them interchangeably,19 cit- ing both Giulietti v. Giulietti, supra, 65 Conn. App. 813 , a case concerning the continuing course of conduct doctrine, and Bouchard v. State Employees Retirement Commission, supra, 328 Conn. 345 , a case predomi- nantly addressing a contin

12021–2021
HOUSING AUTHORITY OF THE CITY OF NEW HAVEN v. Martin green
conn · 2006
1 sentence

2020If a violation is not remediable, it is irrelevant if it con- tinues. ‘‘If a tenant claims that a breach can be and has been remedied and is no longer continuing, the tenant should state those claims in a special defense to the summary process action.’’ (Citations omitted; emphasis altered; internal quotation marks omitted.) Id., 813–14.

12020–2020
Maturo v. State Employees Retirement Commission green
conn · 2017
2 sentences

2018Although substantial deference is given to factual and discretionary determinations of administrative agencies, each of these questions is a purely legal matter over which we exercise plenary review. 5 See, e.g., **359 *1031 Maturo v. State Employees Retirement Commission , 326 Conn. 160 , 171, 162 A.3d 706 (2017) ; Bridgeport Hospital v. Commission on Human Rights & Opportunities , 232 Conn. 91 , 109, 653 A.2d 782 (1995).

2018Although substantial deference is given to factual and discretionary determinations of administrative agencies, each of these questions is a purely legal matter over which we exercise plenary review. 5 See, e.g., **359 *1031 Maturo v. State Employees Retirement Commission , 326 Conn. 160 , 171, 162 A.3d 706 (2017) ; Bridgeport Hospital v. Commission on Human Rights & Opportunities , 232 Conn. 91 , 109, 653 A.2d 782 (1995).

12018–2018
Bridgeport Hospital v. Commission on Human Rights & Opportunities green
conn · 1995
2 sentences

2018Although substantial deference is given to factual and discretionary determinations of administrative agencies, each of these questions is a purely legal matter over which we exercise plenary review. 5 See, e.g., **359 *1031 Maturo v. State Employees Retirement Commission , 326 Conn. 160 , 171, 162 A.3d 706 (2017) ; Bridgeport Hospital v. Commission on Human Rights & Opportunities , 232 Conn. 91 , 109, 653 A.2d 782 (1995).

2018Although substantial deference is given to factual and discretionary determinations of administrative agencies, each of these questions is a purely legal matter over which we exercise plenary review. 5 See, e.g., **359 *1031 Maturo v. State Employees Retirement Commission , 326 Conn. 160 , 171, 162 A.3d 706 (2017) ; Bridgeport Hospital v. Commission on Human Rights & Opportunities , 232 Conn. 91 , 109, 653 A.2d 782 (1995).

12018–2018
Watts v. Chittenden green
conn · 2011
2 sentences

2018They contend that their position is supported by **372 State v. Commission on Human Rights &Opportunities , 211 Conn. 464 , 559 A.2d 1120 (1989) ( CHRO ), and Watts v. Chittenden , 301 Conn. 575 , 22 A.3d 1214 (2011).

2018They contend that their position is supported by **372 State v. Commission on Human Rights &Opportunities , 211 Conn. 464 , 559 A.2d 1120 (1989) ( CHRO ), and Watts v. Chittenden , 301 Conn. 575 , 22 A.3d 1214 (2011).

12018–2018
Bettendorf v. St. Croix County green
ca7 · 2011
1 sentence

2017Wis. 2010) ("the adoption of an ordinance has immediate economic consequences for a land owner; the time for challenging it was within the state period of limitations"), aff'd, 631 F.3d 421 (7th Cir. 2011) ; see also Wellswood Columbia, LLC v. Hebron , supra, United States District Court, Docket No. 3:10-CV-1467 (VLB) (plaintiffs "suffered the continued ill effects of the single act of closing Wellswood Road" rather than continuing unlawful acts necessary to demonstrate **79 a continuing violation); Scott v. Sioux City , supra, 432 N.W.2d at 148 ("[T]he cause of action arises out of the enactm

12017–2017
Bronson v. Leibold neutral
· 1913
2 sentences

2015Co., 98 Conn. 721, 731 , 120 A. 572 (1923) (by accepting noncompliant deliveries for fourteen months, obligee abandoned right to peremptorily put end to further performance by obligor without first giving obligor reasonable notice of its intention to demand strict performance in future); Bronson v. Lei- bold, 87 Conn. 293, 297 , 87 A. 979 (1913) (by accepting multiple noncompliant payments, obligee waived right to insist on forfeiture for noncompliance).

2015Co., 98 Conn. 721, 731 , 120 A. 572 (1923) (by accepting noncompliant deliveries for fourteen months, obligee abandoned right to peremptorily put end to further performance by obligor without first giving obligor reasonable notice of its intention to demand strict performance in future); Bronson v. Lei- bold, 87 Conn. 293, 297 , 87 A. 979 (1913) (by accepting multiple noncompliant payments, obligee waived right to insist on forfeiture for noncompliance).

12015–2015
Remington Arms Union Metallic Cartridge Co. v. Gaynor Manufacturing Co. neutral
· 1923
2 sentences

2015Co., 98 Conn. 721, 731 , 120 A. 572 (1923) (by accepting noncompliant deliveries for fourteen months, obligee abandoned right to peremptorily put end to further performance by obligor without first giving obligor reasonable notice of its intention to demand strict performance in future); Bronson v. Lei- bold, 87 Conn. 293, 297 , 87 A. 979 (1913) (by accepting multiple noncompliant payments, obligee waived right to insist on forfeiture for noncompliance).

2015Co., 98 Conn. 721, 731 , 120 A. 572 (1923) (by accepting noncompliant deliveries for fourteen months, obligee abandoned right to peremptorily put end to further performance by obligor without first giving obligor reasonable notice of its intention to demand strict performance in future); Bronson v. Lei- bold, 87 Conn. 293, 297 , 87 A. 979 (1913) (by accepting multiple noncompliant payments, obligee waived right to insist on forfeiture for noncompliance).

12015–2015
Vaiuso v. Vaiuso green
conn · 1984
1 sentence

2010General Statutes § 22a-44 (b) provides in relevant part: “The Superior Court, in an action brought by the commissioner, municipality, district or any person, shall have jurisdiction to restrain a continuing violation of said sections, to issue orders directing that the violation be corrected or removed and to assess civil penalties pursuant to this section. . . .’’In our jurisprudence, this distinction is significant. “[W]here a statute authorizes a municipality or public entity to seek an injunction in order to enforce compliance with a local zoning ordinance, but says nothing about the injur

12010–2010
DeMartin v. Manson green
conn · 1984
1 sentence

2010General Statutes § 22a-44 (b) provides in relevant part: “The Superior Court, in an action brought by the commissioner, municipality, district or any person, shall have jurisdiction to restrain a continuing violation of said sections, to issue orders directing that the violation be corrected or removed and to assess civil penalties pursuant to this section. . . .’’In our jurisprudence, this distinction is significant. “[W]here a statute authorizes a municipality or public entity to seek an injunction in order to enforce compliance with a local zoning ordinance, but says nothing about the injur

12010–2010
Town of Greenwich v. Kristoff green
connappct · 1984
2 sentences

2010General Statutes § 22a-44 (b) provides in relevant part: “The Superior Court, in an action brought by the commissioner, municipality, district or any person, shall have jurisdiction to restrain a continuing violation of said sections, to issue orders directing that the violation be corrected or removed and to assess civil penalties pursuant to this section. . . .’’In our jurisprudence, this distinction is significant. “[W]here a statute authorizes a municipality or public entity to seek an injunction in order to enforce compliance with a local zoning ordinance, but says nothing about the injur

2010General Statutes § 22a-44 (b) provides in relevant part: “The Superior Court, in an action brought by the commissioner, municipality, district or any person, shall have jurisdiction to restrain a continuing violation of said sections, to issue orders directing that the violation be corrected or removed and to assess civil penalties pursuant to this section. . . .’’In our jurisprudence, this distinction is significant. “[W]here a statute authorizes a municipality or public entity to seek an injunction in order to enforce compliance with a local zoning ordinance, but says nothing about the injur

12010–2010
Napoletano v. CIGNA Healthcare of Connecticut, Inc. green
conn · 1996
12007–2007
Home Depot U. S. A., Inc. v. United States District Court for the Northern District of California green
scotus · 1997
1 sentence

2007All costs, fees and expenses in connection with such action shall be assessed as damages against the violator together with reasonable attorney’s fees which may be allowed, all of which shall be awarded to the commissioner, municipality, district or person which brought such action. . . .” (Emphasis added.) General Statutes § 22a-38 (2) defines “ *[p]erson,’ ” as that term is used in § 22a-44, to mean “any person, firm, partnership, association, corporation, limited liability company, company, organization or legal entity of any kind, including municipal corporations, governmental agencies or

12007–2007
Merchants Bank of California, N. A. v. Mardula green
scotus · 1997
12007–2007
Allentown Mack Sales & Service, Inc. v. National Labor Relations Board green
scotus · 1997
12007–2007
Stephanie J. QUINN, Plaintiff-Appellant, v. GREEN TREE CREDIT CORPORATION, Defendant-Appellee green
ca2 · 1998
12000–2000
Jerry W. Craker v. O.L. McCotter Director, Texas Department of Corrections green
ca5 · 1986
11999–1999
cluster 523284 green
ca10 · 1989
11999–1999
Veeder-Root Co. v. Commission on Human Rights & Opportunities green
conn · 1973
11999–1999
State v. DeFrancesco green
conn · 1994
11995–1995
Jutkowitz v. Department of Health Services green
conn · 1991
11993–1993
Cioffoletti v. Planning & Zoning Commission green
conn · 1989
11993–1993
City of New Haven v. Freedom of Information Commission green
conn · 1988
11993–1993
Conservation Commission v. Price green
connappct · 1985
11992–1992
Raymond A. West, Sr. v. Itt Continental Baking Co., Bakery and Confectionary Workers International Union of America, Afl-Cio and Its Local No. 358 green
ca4 · 1982
11987–1987

Statutes the citing opinions construe

CT § Conn. Gen. Stat. § 22a-36 (5) CT § Conn. Gen. Stat. § 51-199 (5) CT § Conn. Gen. Stat. § 22a-44 (4) CT § Conn. Gen. Stat. § 4-183 (4) CT § Conn. Gen. Stat. § 22a-16 (3) CT § Conn. Gen. Stat. § 22a-38 (3) CT § Conn. Gen. Stat. § 22a-40 (3) CT § Conn. Gen. Stat. § 42-110a (3) CT § Conn. Gen. Stat. § 46a-51 (3) CT § Conn. Gen. Stat. § 46a-60 (3) CT § Conn. Gen. Stat. § 46a-82 (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.

Where else courts name it

CA 155 (1941–2026) NY 113 (1910–2026) TX 101 (1960–2025) IL 91 (1910–2026) NJ 86 (1971–2026) MA 60 (1971–2025) PA 49 (1932–2026) NC 32 (1969–2025) AL 30 (1984–2023) WA 30 (1984–2026) OH 25 (1995–2026) MD 24 (1972–2021) CT 24 (1987–2024) MO 22 (1980–2025) FL 21 (1974–2025) MN 21 (1983–2025) MI 19 (1972–2024) IA 18 (1990–2021) GA 18 (1940–2024) DC 17 (1980–2020) TN 17 (1995–2026) LA 16 (1979–2019) WV 14 (1981–2025) WI 13 (1924–2026) VA 12 (1999–2025) CO 12 (1989–2026) VT 11 (1996–2026) OK 11 (1916–2014) ME 9 (1996–2025) WY 8 (1939–2000) NM 8 (1995–2018) AZ 8 (2008–2021) KS 7 (1980–2025) NH 7 (2006–2016) OR 7 (1977–2023) DE 6 (2015–2024) IN 6 (1984–2023) RI 6 (2005–2026) MS 6 (1940–2018) ID 5 (1984–2008) AK 5 (1994–2022) MT 5 (1999–2022) NE 4 (1929–2007) VI 4 (2005–2024) SD 4 (1980–2000) KY 4 (1992–2023) SC 3 (2015–2018) UT 2 (1992–2019) ND 2 (2009–2020)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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