collateral estoppel doctrine in Connecticut

2001State v. Ellis, 197 Conn. 436, 466 , 497 A.2d 974 (1985), on appeal after remand sub nom.

2001State v. Ellis, 197 Conn. 436, 466 , 497 A.2d 974 (1985), on appeal after remand sub nom.

2018"The applicability of the doctrine of collateral estoppel, like the applicability of the closely related doctrine of res judicata, presents a question of law that we review de novo." (Footnote omitted.) Cumberland Farms, Inc. v. Groton , 262 Conn. 45 , 57-58, 808 A.2d 1107 (2002).

2018"The applicability of the doctrine of collateral estoppel, like the applicability of the closely related doctrine of res judicata, presents a question of law that we review de novo." (Footnote omitted.) Cumberland Farms, Inc. v. Groton , 262 Conn. 45 , 57-58, 808 A.2d 1107 (2002).

2014The Connecticut Supreme Court has stated that “ [collateral estoppel, or issue preclusion, is that aspect of res judicata which prohibits the relitigation of an issue when that issue was actually litigated and necessarily determined in a prior action between the same parties upon a different claim.” In re Juvenile Appeal (83-DE), 190 Conn. 310, 316 , 460 A.2d 1277 (1983).

2014The Connecticut Supreme Court has stated that “ [collateral estoppel, or issue preclusion, is that aspect of res judicata which prohibits the relitigation of an issue when that issue was actually litigated and necessarily determined in a prior action between the same parties upon a different claim.” In re Juvenile Appeal (83-DE), 190 Conn. 310, 316 , 460 A.2d 1277 (1983).

1997Co. , 236 Conn. 582 , 674 A.2d 1290 (1996), the Connecticut Supreme Court "observed that res judicata, like the doctrine of collateral estoppel, promote[s] judicial economy by preventing relitigation of issues or claims previously resolved ." (Internal quotation marks omitted.) Connecticut Natural Gas Corp. v. Miller , 239 Conn. 313 , 322 , 684 A.2d 1173 (1996) "[A] decision whether to apply the doctrine of res judicata to claims that have not actually been litigated should be made based upon a consideration of the doctrine's underlying policies, namely, the interests of the defendant and of t

1997Co. , 236 Conn. 582 , 674 A.2d 1290 (1996), the Connecticut Supreme Court "observed that res judicata, like the doctrine of collateral estoppel, promote[s] judicial economy by preventing relitigation of issues or claims previously resolved ." (Internal quotation marks omitted.) Connecticut Natural Gas Corp. v. Miller , 239 Conn. 313 , 322 , 684 A.2d 1173 (1996) "[A] decision whether to apply the doctrine of res judicata to claims that have not actually been litigated should be made based upon a consideration of the doctrine's underlying policies, namely, the interests of the defendant and of t

2007See, e.g., [id.], 422, 429 (preclusion doctrines do not bar relitigation of property damage claim, which initially was litigated in small claims court, in subsequent personal injury action pending on regular civil docket even though both small claims and personal injury actions were predicated on same events); Stratford v. International Assn, of Firefighters, AFL-CIO, Local 998, supra, 248 Conn. 124 -25 (second arbitration panel need not give preclusive effect to issues decided by first arbitration panel even when decisions of both panels involve same parties and interpretation of same contrac

2007See, e.g., [id.], 422, 429 (preclusion doctrines do not bar relitigation of property damage claim, which initially was litigated in small claims court, in subsequent personal injury action pending on regular civil docket even though both small claims and personal injury actions were predicated on same events); Stratford v. International Assn, of Firefighters, AFL-CIO, Local 998, supra, 248 Conn. 124 -25 (second arbitration panel need not give preclusive effect to issues decided by first arbitration panel even when decisions of both panels involve same parties and interpretation of same contrac

2018See, e.g., Bath Iron Works Corp. v. Director, Office of Workers' Compensation Programs , 125 F.3d 18 , 22 (1st Cir. 1997) ('[c]ertainly a difference in the legal standards pertaining to two proceedings may defeat the use of collateral estoppel ... [b]ut this is so only where the difference undermines the rationale of the doctrine' ...); Newport News Shipbuilding & Dry Dock Co. v. Director, Office of Workers' Compensation Programs , 583 F.2d 1273 , 1279 (4th Cir. 1978) ('[r]elitigation of an issue is not precluded by the doctrine of collateral estoppel where the party against whom the doctrine

2011See, e.g., Bath Iron Works Corp. v. Director, Office of Workers’ Compensation Programs, 125 F.3d 18, 22 (1st Cir. 1997) (‘[c]ertainly a difference in the legal standards pertaining to two proceedings may defeat the use of collateral estoppel . . . [b]ut this is so only where the difference undermines the rationale of the doctrine’ [citations omitted]); Newport News Shipbuilding & Dry Dock Co. v. Director, Office of Workers’ Compensation Programs, 583 F.2d 1273, 1279 (4th Cir. 1978) (‘[r]elitigation of an issue is not precluded by the doctrine of collateral estoppel where the party against whom

2018See, e.g., Bath Iron Works Corp. v. Director, Office of Workers' Compensation Programs , 125 F.3d 18 , 22 (1st Cir. 1997) ('[c]ertainly a difference in the legal standards pertaining to two proceedings may defeat the use of collateral estoppel ... [b]ut this is so only where the difference undermines the rationale of the doctrine' ...); Newport News Shipbuilding & Dry Dock Co. v. Director, Office of Workers' Compensation Programs , 583 F.2d 1273 , 1279 (4th Cir. 1978) ('[r]elitigation of an issue is not precluded by the doctrine of collateral estoppel where the party against whom the doctrine

2011See, e.g., Bath Iron Works Corp. v. Director, Office of Workers’ Compensation Programs, 125 F.3d 18, 22 (1st Cir. 1997) (‘[c]ertainly a difference in the legal standards pertaining to two proceedings may defeat the use of collateral estoppel . . . [b]ut this is so only where the difference undermines the rationale of the doctrine’ [citations omitted]); Newport News Shipbuilding & Dry Dock Co. v. Director, Office of Workers’ Compensation Programs, 583 F.2d 1273, 1279 (4th Cir. 1978) (‘[r]elitigation of an issue is not precluded by the doctrine of collateral estoppel where the party against whom

2018See, e.g., Bath Iron Works Corp. v. Director, Office of Workers' Compensation Programs , 125 F.3d 18 , 22 (1st Cir. 1997) ('[c]ertainly a difference in the legal standards pertaining to two proceedings may defeat the use of collateral estoppel ... [b]ut this is so only where the difference undermines the rationale of the doctrine' ...); Newport News Shipbuilding & Dry Dock Co. v. Director, Office of Workers' Compensation Programs , 583 F.2d 1273 , 1279 (4th Cir. 1978) ('[r]elitigation of an issue is not precluded by the doctrine of collateral estoppel where the party against whom the doctrine

2011See, e.g., Bath Iron Works Corp. v. Director, Office of Workers’ Compensation Programs, 125 F.3d 18, 22 (1st Cir. 1997) (‘[c]ertainly a difference in the legal standards pertaining to two proceedings may defeat the use of collateral estoppel . . . [b]ut this is so only where the difference undermines the rationale of the doctrine’ [citations omitted]); Newport News Shipbuilding & Dry Dock Co. v. Director, Office of Workers’ Compensation Programs, 583 F.2d 1273, 1279 (4th Cir. 1978) (‘[r]elitigation of an issue is not precluded by the doctrine of collateral estoppel where the party against whom

2011The Supreme Court stated that because the meaning of ‘fine furniture’ was neither litigated by the parties nor decided by the [Superior Court] in the site plan case, ‘the [Superior Court] did not render final judgment on an issue that would preclude the board, under the doctrine of collateral estoppel, from ensuring in the cease and desist case that the plaintiffs’ actual use complied with its site plan application to sell fine furniture.’ Id.

2011R & R Pool & Patio, Inc. v. Zoning Board of Appeals, [ 257 Conn. 456, 475 , 778 A.2d 61 (2001)].

2000The judicial interests of economy, stability, and finality — the very interests that underpin the doctrine of collateral estoppel, Walsh v. Town of Stonington Water Pollution Control Authority, supra, 250 Conn. at 460 — are applicable in each setting.

2000Collateral estoppel means simply that when an issue of ultimate fact has once been determined by a valid and final judgment, that issue cannot again be litigated between the same parties in any future lawsuit.” (Citation omitted; internal quotation marks omitted.) Walsh v. Stonington Water Pollution Control Authority, 250 Conn. 443, 460-61 , 736 A.2d 811 (1999).

2023Although the Probate Court actually and necessarily found that the 2014 will ‘‘express[ed] [the decedent’s] actual testamentary desires’’; (emphasis added) Bassford v. Bassford, 180 Conn. App. 331, 355 , 183 A.3d 680 (2018); it made no factual findings, and was not required to make any such findings, regarding the decedent’s contractual desires, i.e., whether the decedent intended to leave the plaintiff the Solon assets via an amended antenuptial agreement and, if so, whether the defendants tortiously interfered with the consummation of the proposed amended agreement.11 Accordingly, the plaint

2023Although the Probate Court actually and necessarily found that the 2014 will ‘‘express[ed] [the decedent’s] actual testamentary desires’’; (emphasis added) Bassford v. Bassford, 180 Conn. App. 331, 355 , 183 A.3d 680 (2018); it made no factual findings, and was not required to make any such findings, regarding the decedent’s contractual desires, i.e., whether the decedent intended to leave the plaintiff the Solon assets via an amended antenuptial agreement and, if so, whether the defendants tortiously interfered with the consummation of the proposed amended agreement.11 Accordingly, the plaint

2023See Corcoran v. Dept. of Social Services, supra, 271 Conn. 690 (administrative action regarding plaintiff’s entitlement to Medicaid benefits was not collaterally estopped by Probate Court decree finding that trust assets were held in special needs trust ‘‘because the issue decided by the Probate Court, namely, that the trust was not available to the plaintiff’s creditors, is not identical to the issue before the hearing officer, namely, whether the trust constituted an asset available to the plaintiff’’ (emphasis in original)); Peterson v. iCare Management, LLC, 203 Conn. App. 777 , 793, 250 A

2023See Corcoran v. Dept. of Social Services, supra, 271 Conn. 690 (administrative action regarding plaintiff’s entitlement to Medicaid benefits was not collaterally estopped by Probate Court decree finding that trust assets were held in special needs trust ‘‘because the issue decided by the Probate Court, namely, that the trust was not available to the plaintiff’s creditors, is not identical to the issue before the hearing officer, namely, whether the trust constituted an asset available to the plaintiff’’ (emphasis in original)); Peterson v. iCare Management, LLC, 203 Conn. App. 777 , 793, 250 A

2023See Kramer v. Freedman, 272 So. 2d 195, 199 (Fla. App.) (malicious interference with inheritance claim was barred by collateral estoppel effect of prior probate proceeding regarding revocation of decedent’s will), cert. dis- charged, 295 So. 2d 97 (Fla. 1973); Mancuso v. Lahman, Docket No. 1-17-0185, 2018 WL 4201754 , *1 (Ill. App. August 30, 2018) (‘‘[the] [t]rial court’s [rendering] of summary judgment on [the tortious interference with inheritance] claims was properly based on [the collateral estoppel] doctrine, as [the] court in [the] prior will contest had already conclusively ruled that

2023See Kramer v. Freedman, 272 So. 2d 195, 199 (Fla. App.) (malicious interference with inheritance claim was barred by collateral estoppel effect of prior probate proceeding regarding revocation of decedent’s will), cert. dis- charged, 295 So. 2d 97 (Fla. 1973); Mancuso v. Lahman, Docket No. 1-17-0185, 2018 WL 4201754 , *1 (Ill. App. August 30, 2018) (‘‘[the] [t]rial court’s [rendering] of summary judgment on [the tortious interference with inheritance] claims was properly based on [the collateral estoppel] doctrine, as [the] court in [the] prior will contest had already conclusively ruled that

2023See Corcoran v. Dept. of Social Services, supra, 271 Conn. 690 (administrative action regarding plaintiff’s entitlement to Medicaid benefits was not collaterally estopped by Probate Court decree finding that trust assets were held in special needs trust ‘‘because the issue decided by the Probate Court, namely, that the trust was not available to the plaintiff’s creditors, is not identical to the issue before the hearing officer, namely, whether the trust constituted an asset available to the plaintiff’’ (emphasis in original)); Peterson v. iCare Management, LLC, 203 Conn. App. 777 , 793, 250 A

2023See Corcoran v. Dept. of Social Services, supra, 271 Conn. 690 (administrative action regarding plaintiff’s entitlement to Medicaid benefits was not collaterally estopped by Probate Court decree finding that trust assets were held in special needs trust ‘‘because the issue decided by the Probate Court, namely, that the trust was not available to the plaintiff’s creditors, is not identical to the issue before the hearing officer, namely, whether the trust constituted an asset available to the plaintiff’’ (emphasis in original)); Peterson v. iCare Management, LLC, 203 Conn. App. 777 , 793, 250 A

2023See Weizmann Institute of Science v. Neschis, 229 F. Supp. 2d 234, 249 (S.D.N.Y. 2002) (collateral estoppel effect of prior probate action did ‘‘not preclude the [plaintiffs] from raising issues and challenging those documents, if any, that were not part of the probate proceeding’’); Arroyo-Graulau v. Merrill Lynch Pierce, Fenner & Smith, Inc., 135 App. Div. 3d 1, 4, 19 N.Y.S.3d 221 (2015) (plaintiff’s claims regarding delivery of estate account assets were not barred by collateral estoppel effect of prior Probate Court judgment because sole issue in prior action ‘‘was whether the 2008 will sh

2023See Weizmann Institute of Science v. Neschis, 229 F. Supp. 2d 234, 249 (S.D.N.Y. 2002) (collateral estoppel effect of prior probate action did ‘‘not preclude the [plaintiffs] from raising issues and challenging those documents, if any, that were not part of the probate proceeding’’); Arroyo-Graulau v. Merrill Lynch Pierce, Fenner & Smith, Inc., 135 App. Div. 3d 1, 4, 19 N.Y.S.3d 221 (2015) (plaintiff’s claims regarding delivery of estate account assets were not barred by collateral estoppel effect of prior Probate Court judgment because sole issue in prior action ‘‘was whether the 2008 will sh