typographical error (Connecticut) · Go Syfert
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typographical error in Connecticut

19 Connecticut opinions name it 3 courts 1985–2025 2 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 (5)

CaseFollowedCited
Marie L. Hill v. United States Fidelity and Guaranty Companygreen
ca5 · 1970 · cited in 2 Connecticut opinions naming this issue, 1997–2019
2 sentences

2019We note that the language in the introductory portion of this section, "to [perform] his undertaking," apparently included a typographical error and used the word "protect" instead of "perform." See Hill v. United States Fidelity & Guaranty Co. , 428 F.2d 112 , 115 n.5 (5th Cir. 1970) ("[t]he reporter for this edition of the Restatement, by a letter to counsel furnished to this court, has verified that the word 'protect' which appears at this point is a typographical error and should read 'perform' ").

1997(Emphasis added.) Hill v. United States Fidelity and Guaranty Company , 428 F.2d 112 , 115 n. 5 (5th Cir. 1970).

12
Spilke v. Wicklowgreen
connappct · 2012 · cited in 1 Connecticut opinions naming this issue, 2025–2025
2 sentences

2025Also, if the amendment interjects material new issues, the adversary is entitled to reasonable opportu- nity to meet them by pleading and proof.’’ (Internal quotation marks omitted.) Id., 745 ; see also, e.g., Spilke v. Wicklow, 138 Conn. App. 251, 270 , 53 A.3d 245 (2012) (filing of four amended complaints did not extinguish default where, ‘‘[a]lthough the complaints differed in some respects from the original complaint, the substan- tive allegations remained the same’’), cert. denied, 307 Conn. 945 , 60 A.3d 737 (2013); Willamette Management Associates, Inc. v. Palczynski, 134 Conn. App. 58,

2025Also, if the amendment interjects material new issues, the adversary is entitled to reasonable opportu- nity to meet them by pleading and proof.’’ (Internal quotation marks omitted.) Id., 745 ; see also, e.g., Spilke v. Wicklow, 138 Conn. App. 251, 270 , 53 A.3d 245 (2012) (filing of four amended complaints did not extinguish default where, ‘‘[a]lthough the complaints differed in some respects from the original complaint, the substan- tive allegations remained the same’’), cert. denied, 307 Conn. 945 , 60 A.3d 737 (2013); Willamette Management Associates, Inc. v. Palczynski, 134 Conn. App. 58,

11
State v. Bluegreen
conn · 1994 · cited in 1 Connecticut opinions naming this issue, 2014–2014
2 sentences

2014For convenience, we will refer to this claim as the defendants’ first amendment claim. 6 See, e.g., State v. Blue, 230 Conn. 109 , 113 n.3, 644 A.2d 859 (1994) (“[T]he transcript indicate[d] that it was the ‘Court’ that said ‘I understand what you’re saying, yes.’ It is clear, however, from the response and its context that this was a typographical error, and that in fact the response was that of the defendant.”). 7 The defendants proffer the following theories as alternative causes for the plaintiffs emotional distress: the death of the plaintiffs daughter by suicide one month before Bill Smo

2014For convenience, we will refer to this claim as the defendants’ first amendment claim. 6 See, e.g., State v. Blue, 230 Conn. 109 , 113 n.3, 644 A.2d 859 (1994) (“[T]he transcript indicate[d] that it was the ‘Court’ that said ‘I understand what you’re saying, yes.’ It is clear, however, from the response and its context that this was a typographical error, and that in fact the response was that of the defendant.”). 7 The defendants proffer the following theories as alternative causes for the plaintiffs emotional distress: the death of the plaintiffs daughter by suicide one month before Bill Smo

11
Waters v. Autuorigreen
conn · 1996 · cited in 1 Connecticut opinions naming this issue, 1997–1997
1 sentence

1997It should also be noted that almost all of the reported cases CT Page 465 interpreting § 324A; see, e.g., Waters v. Autuori , 236 Conn. 820 , 832 n. 8 (1996); inadvertently incorporate a typographical error in the published text of the rule which states that "[o]ne who undertakes . . . to render services to another . . . is subject to liability to the third person for physical harm resulting from his failure to exercise reasonable care to protect his undertaking, if . . . (b) he has undertaken to perform a duty owed by the other to the third person . . .".

11
United States v. Janice Wallace, United States of America v. Elmore Penngreen
ca9 · 1988 · cited in 1 Connecticut opinions naming this issue, 1989–1989
1 sentence

1989See United States v. Wallace, supra; Gonzales I, supra. We also note that the state inadvertently demonstrates the significance of original statements by stating at one point in its brief that Gray “never waivered on her claim that the defendant asked her for money, then pulled a knife from his gym bag . . . . ” (Emphasis added.) If the state could overlook this typographical error before filing its brief, we find it peculiar for it to insist that the New Haven police department’s stenographer prepared a “verbatim” copy of the Epps recording. 5 A “preference” for the original tape recording el

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 (21)

CaseCitedYears
Dyck O'Neal, Inc. v. Wynne neutral
connappct · 1999
2 sentences

2012Moreover, this clearly is not a case where a plaintiff was misnamed because of a typographical error, the fault of which was not attributable to the plaintiff; Dyck O’Neal, Inc. v. Wynne, 56 Conn. App. 161, 166-67 , 742 A.2d 393 (1999); or because of a “ ‘poor and superfluous choice of words,’ ” as was the case in Young v. Vlahos, supra, 103 Conn. App. 478 .

2012Moreover, this clearly is not a case where a plaintiff was misnamed because of a typographical error, the fault of which was not attributable to the plaintiff; Dyck O’Neal, Inc. v. Wynne, 56 Conn. App. 161, 166-67 , 742 A.2d 393 (1999); or because of a “ ‘poor and superfluous choice of words,’ ” as was the case in Young v. Vlahos, supra, 103 Conn. App. 478 .

22005–2012
Willamette Management Associates, Inc. v. Palczynski green
connappct · 2012
2 sentences

2025Also, if the amendment interjects material new issues, the adversary is entitled to reasonable opportu- nity to meet them by pleading and proof.’’ (Internal quotation marks omitted.) Id., 745 ; see also, e.g., Spilke v. Wicklow, 138 Conn. App. 251, 270 , 53 A.3d 245 (2012) (filing of four amended complaints did not extinguish default where, ‘‘[a]lthough the complaints differed in some respects from the original complaint, the substan- tive allegations remained the same’’), cert. denied, 307 Conn. 945 , 60 A.3d 737 (2013); Willamette Management Associates, Inc. v. Palczynski, 134 Conn. App. 58,

2025Also, if the amendment interjects material new issues, the adversary is entitled to reasonable opportu- nity to meet them by pleading and proof.’’ (Internal quotation marks omitted.) Id., 745 ; see also, e.g., Spilke v. Wicklow, 138 Conn. App. 251, 270 , 53 A.3d 245 (2012) (filing of four amended complaints did not extinguish default where, ‘‘[a]lthough the complaints differed in some respects from the original complaint, the substan- tive allegations remained the same’’), cert. denied, 307 Conn. 945 , 60 A.3d 737 (2013); Willamette Management Associates, Inc. v. Palczynski, 134 Conn. App. 58,

12025–2025
Atelier Constantin Popescu, LLC v. JC Corp. green
connappct · 2012
2 sentences

2022The plaintiff, in its appellate brief, does not address this apparent discrepancy. 9 The introductory clause of the lease defines Commerce Park as the ‘‘Landlord.’’ The parties do not appear to dispute that ‘‘Landlord’’ as used in paragraph 28 (b) means Commerce Park. 10 Quoting Atelier Constantin Popescu, LLC v. JC Corp., 134 Conn. App. 731, 757 , 49 A.3d 1003 (2012), in rendering judgment in the plaintiff’s favor on its negligence claim against Commerce Park, Judge Krumeich stated that ‘‘[t]here is no question that a duty of care may arise out of a contract, but when the claim is brought aga

2022The plaintiff, in its appellate brief, does not address this apparent discrepancy. 9 The introductory clause of the lease defines Commerce Park as the ‘‘Landlord.’’ The parties do not appear to dispute that ‘‘Landlord’’ as used in paragraph 28 (b) means Commerce Park. 10 Quoting Atelier Constantin Popescu, LLC v. JC Corp., 134 Conn. App. 731, 757 , 49 A.3d 1003 (2012), in rendering judgment in the plaintiff’s favor on its negligence claim against Commerce Park, Judge Krumeich stated that ‘‘[t]here is no question that a duty of care may arise out of a contract, but when the claim is brought aga

12022–2022
State v. Allen green
conn · 2006
1 sentence

2012Defendant also cites as controlling law the case of Shore v. Haverson Architecture & Design, P.C., 92 Conn. App. 469 , 886 A.2d 837 (2005), cert. denied, 277 Conn. 907 , 894 A.2d 988 (2006).

12012–2012
Fileccia v. Nationwide Property & Casualty Insurance green
conn · 2006
1 sentence

2012Defendant also cites as controlling law the case of Shore v. Haverson Architecture & Design, P.C., 92 Conn. App. 469 , 886 A.2d 837 (2005), cert. denied, 277 Conn. 907 , 894 A.2d 988 (2006).

12012–2012
Shore v. Haverson Architecture & Design, P.C. green
connappct · 2005
2 sentences

2012Defendant also cites as controlling law the case of Shore v. Haverson Architecture & Design, P.C., 92 Conn. App. 469 , 886 A.2d 837 (2005), cert. denied, 277 Conn. 907 , 894 A.2d 988 (2006).

2012Defendant also cites as controlling law the case of Shore v. Haverson Architecture & Design, P.C., 92 Conn. App. 469 , 886 A.2d 837 (2005), cert. denied, 277 Conn. 907 , 894 A.2d 988 (2006).

12012–2012
State v. Kitchens green
conn · 2011
2 sentences

2011Defense counsel corrected a typographical error and then stated that “the only thing else I’d like to say is that to the extent that the court’s final charge differs from the defendant’s request to charge we take exception.” Our resolution of the defendant’s instructional claims turns on our recent decision in State v. Kitchens, 299 Conn. 447 , 10 A.3d 942 (2011).

2011Defense counsel corrected a typographical error and then stated that "the only thing else I'd like to say is that to the extent that the court's final charge differs from the defendant's request to charge we take exception." Our resolution of the defendant's instructional claims turns on our recent decision in State v. Kitchens, 299 *677 Conn. at 447, 10 A.3d 942 (2011).

12011–2011
State v. Eisele green
washctapp · 1973
1 sentence

2009Id., 175 .

12009–2009
Pantlin & Chananie Development Corp. v. Hartford Cement & Building Supply Co. green
conn · 1985
2 sentences

2004In Pantlin & Chananie Development Corp. v. Hartford Cement & Building Supply Co., 196 Conn. 233, 240 , 492 A.2d 159 (1985), our Supreme Court stated that “to set aside a judgment passed upon default [pursuant to General Statutes § 52-212], there must be a showing that: (1) a good defense existed at the time judgment was rendered; and (2) the party seeking to set aside the judgment was prevented from [prosecuting or] appearing because of mistake, accident, or other reasonable cause.” The plaintiffs principal argument, both in its objection to the defendants’ motion to open and in its appellate

2004In Pantlin & Chananie Development Corp. v. Hartford Cement & Building Supply Co., 196 Conn. 233, 240 , 492 A.2d 159 (1985), our Supreme Court stated that “to set aside a judgment passed upon default [pursuant to General Statutes § 52-212], there must be a showing that: (1) a good defense existed at the time judgment was rendered; and (2) the party seeking to set aside the judgment was prevented from [prosecuting or] appearing because of mistake, accident, or other reasonable cause.” The plaintiffs principal argument, both in its objection to the defendants’ motion to open and in its appellate

12004–2004
Hartford Accident & Indemnity Co. v. Chung green
connsuperct · 1981
2 sentences

2001"It is, after all, the facts alleged which determine the cause of action, and not the nomenclature employed." Hartford Accident Indemnity Co. v. Chung , 37 Conn. Sup. 587 , 595 , 429 A.2d 158 (App. Sess. 1981).

2001"It is, after all, the facts alleged which determine the cause of action, and not the nomenclature employed." Hartford Accident Indemnity Co. v. Chung , 37 Conn. Sup. 587 , 595 , 429 A.2d 158 (App. Sess. 1981).

12001–2001
Concept Associates, Ltd. v. Board of Tax Review green
conn · 1994
1 sentence

1996In accordance with Concept Associates, Ltd., v. Board of Tax Review, 229 Conn. 618 (1994) the court grants leave to amend the complaint and denies defendants' Motion to Dismiss.

11996–1996
Kimberly-Clark Corp. v. Dubno green
conn · 1987
2 sentences

1993An estoppel claim is "predicated on proof of two essential elements: the party against whom estoppel is claimed must do or say something calculated or intended to induce another party to believe that certain facts exist and to act on that belief; and the other party must change its position in reliance on those facts, thereby incurring some injury." (Citations omitted.) Kimberly Clark Corp. v. Dubno, 204 Conn. 137 , 148 , 527 A.2d 679 (1987), quoting Zoning Commission v. Lescynski, 188 Conn. 724 , 731 , 453 A.2d 1144 (1982). "[E]stoppel against a public agency is limited and may be invoked: (1

1993An estoppel claim is "predicated on proof of two essential elements: the party against whom estoppel is claimed must do or say something calculated or intended to induce another party to believe that certain facts exist and to act on that belief; and the other party must change its position in reliance on those facts, thereby incurring some injury." (Citations omitted.) Kimberly Clark Corp. v. Dubno, 204 Conn. 137 , 148 , 527 A.2d 679 (1987), quoting Zoning Commission v. Lescynski, 188 Conn. 724 , 731 , 453 A.2d 1144 (1982). "[E]stoppel against a public agency is limited and may be invoked: (1

11993–1993
Zoning Commission v. Lescynski green
conn · 1982
2 sentences

1993An estoppel claim is "predicated on proof of two essential elements: the party against whom estoppel is claimed must do or say something calculated or intended to induce another party to believe that certain facts exist and to act on that belief; and the other party must change its position in reliance on those facts, thereby incurring some injury." (Citations omitted.) Kimberly Clark Corp. v. Dubno, 204 Conn. 137 , 148 , 527 A.2d 679 (1987), quoting Zoning Commission v. Lescynski, 188 Conn. 724 , 731 , 453 A.2d 1144 (1982). "[E]stoppel against a public agency is limited and may be invoked: (1

1993An estoppel claim is "predicated on proof of two essential elements: the party against whom estoppel is claimed must do or say something calculated or intended to induce another party to believe that certain facts exist and to act on that belief; and the other party must change its position in reliance on those facts, thereby incurring some injury." (Citations omitted.) Kimberly Clark Corp. v. Dubno, 204 Conn. 137 , 148 , 527 A.2d 679 (1987), quoting Zoning Commission v. Lescynski, 188 Conn. 724 , 731 , 453 A.2d 1144 (1982). "[E]stoppel against a public agency is limited and may be invoked: (1

11993–1993
Hoxie v. Payne green
conn · 1874
2 sentences

1992The defendants filed an objection to the plaintiff's request to amend on the ground that the "defect sought to be amended is more than a typographical error and the amendment is untimely." In the course of the hearing on the motion, the plaintiff argued that typographical errors of this kind frequently occur at the close of the current year and the beginning of the new year and can therefore be properly characterized as "circumstantial errors, mistakes or defects" within the meaning of 52-123 , which provides that no such "writ, pleading, judgment or any kind of proceeding in court . . . shall

1992The defendants filed an objection to the plaintiff's request to amend on the ground that the "defect sought to be amended is more than a typographical error and the amendment is untimely." In the course of the hearing on the motion, the plaintiff argued that typographical errors of this kind frequently occur at the close of the current year and the beginning of the new year and can therefore be properly characterized as "circumstantial errors, mistakes or defects" within the meaning of 52-123 , which provides that no such "writ, pleading, judgment or any kind of proceeding in court . . . shall

11992–1992
State v. Lubesky green
conn · 1985
2 sentences

1988We observe that when defense counsel, actually present in the courtroom at the time of a claimed error, fails to object and except, we may presume that he did not view the allegedly objectionable language to be as egregious as appellate counsel now urges; nor did he view the error as so prejudicial that his client’s right to a fair trial was seriously jeopardized. 5 State v. Lubesky, 195 Conn. 475, 484 , 488 A.2d 1239 (1985).

1988We observe that when defense counsel, actually present in the courtroom at the time of a claimed error, fails to object and except, we may presume that he did not view the allegedly objectionable language to be as egregious as appellate counsel now urges; nor did he view the error as so prejudicial that his client’s right to a fair trial was seriously jeopardized. 5 State v. Lubesky, 195 Conn. 475, 484 , 488 A.2d 1239 (1985).

11988–1988
State v. Delmonaco green
conn · 1984
2 sentences

1988We must, however, “consider only the information that was actually before the issuing judge at the time he or she signed the warrant.” State v. Delmonaco, 194 Conn. 331, 337 , 481 A.2d 40 , cert. denied, 469 U.S. 1036 , 105 S. Ct. 511 , 83 L.

1988We must, however, “consider only the information that was actually before the issuing judge at the time he or she signed the warrant.” State v. Delmonaco, 194 Conn. 331, 337 , 481 A.2d 40 , cert. denied, 469 U.S. 1036 , 105 S. Ct. 511 , 83 L.

11988–1988
Berkovitz v. Islamic Republic of Iran green
scotus · 1984
1 sentence

1988We must, however, “consider only the information that was actually before the issuing judge at the time he or she signed the warrant.” State v. Delmonaco, 194 Conn. 331, 337 , 481 A.2d 40 , cert. denied, 469 U.S. 1036 , 105 S. Ct. 511 , 83 L.

11988–1988
S. E. Johnson Co. v. Arthur S. Langenderfer, Inc. green
scotus · 1984
1 sentence

1988We must, however, “consider only the information that was actually before the issuing judge at the time he or she signed the warrant.” State v. Delmonaco, 194 Conn. 331, 337 , 481 A.2d 40 , cert. denied, 469 U.S. 1036 , 105 S. Ct. 511 , 83 L.

11988–1988
Spaulding v. University of Washington green
scotus · 1984
1 sentence

1988We must, however, “consider only the information that was actually before the issuing judge at the time he or she signed the warrant.” State v. Delmonaco, 194 Conn. 331, 337 , 481 A.2d 40 , cert. denied, 469 U.S. 1036 , 105 S. Ct. 511 , 83 L.

11988–1988
State v. Geyer green
conn · 1984
2 sentences

1985State v. Geyer, 194 Conn. 1, 17 , 480 A.2d 489 (1984); Allied Plywood, Inc. v. Planning & Zoning Commission, 2 Conn. App. 506, 509 , 480 A.2d 584 (1984).

1985State v. Geyer, 194 Conn. 1, 17 , 480 A.2d 489 (1984); Allied Plywood, Inc. v. Planning & Zoning Commission, 2 Conn. App. 506, 509 , 480 A.2d 584 (1984).

11985–1985
Allied Plywood, Inc. v. Planning & Zoning Commission green
connappct · 1984
2 sentences

1985State v. Geyer, 194 Conn. 1, 17 , 480 A.2d 489 (1984); Allied Plywood, Inc. v. Planning & Zoning Commission, 2 Conn. App. 506, 509 , 480 A.2d 584 (1984).

1985State v. Geyer, 194 Conn. 1, 17 , 480 A.2d 489 (1984); Allied Plywood, Inc. v. Planning & Zoning Commission, 2 Conn. App. 506, 509 , 480 A.2d 584 (1984).

11985–1985

Statutes the citing opinions construe

CT § Conn. Gen. Stat. § 42-110a (3) CT § Conn. Gen. Stat. § 52-45a (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

TX 173 (1907–2025) NY 127 (1910–2026) CA 99 (1941–2026) PA 81 (1931–2026) OH 77 (1958–2026) IL 63 (1951–2026) LA 46 (1941–2025) GA 37 (1900–2021) MO 27 (1913–2025) IA 24 (1931–2025) IN 22 (1955–2025) WI 22 (1956–2025) FL 22 (1937–2024) NM 20 (1992–2022) WA 19 (1965–2025) CT 19 (1985–2025) OK 18 (1910–2024) NJ 18 (1982–2024) VA 16 (1932–2026) AL 16 (1917–2018) MI 16 (1978–2026) OR 16 (1990–2026) TN 16 (1901–2021) MA 14 (1970–2024) AR 14 (1941–2021) KS 13 (1904–2019) ID 13 (1949–2026) NC 13 (1896–2018) MD 13 (1997–2026) AZ 12 (1994–2023) WV 10 (1996–2024) DE 10 (2012–2025) MS 9 (1997–2016) NE 7 (1896–2025) KY 7 (1966–2026) UT 7 (1950–2026) AK 7 (1968–2024) RI 7 (1984–2024) MT 6 (1994–2009) CO 6 (1979–2020) HI 5 (1968–2026) ME 5 (2010–2020) MN 5 (1986–2016) DC 4 (1976–2006) SC 4 (1930–2005) WY 4 (1983–2011) SD 3 (1934–2015) ND 2 (1979–1987) NH 2 (1953–2007) NV 2 (2004–2017)

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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