absence of a colorable claim in Connecticut

14 Connecticut opinions name it 3 courts 2002–2025 5 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 (9)

Case	Followed	Cited
State v. Taylorgreen connappct · 2005 · cited in 2 Connecticut opinions naming this issue, 2016–2017 2 sentences 2017See id., at 793-94 , 882 A.2d 682 ." (Emphasis added; internal quotation marks omitted.) State v. Delgado , 323 Conn. 801 , 810, 151 A.3d 345 (2016). 2017See id., at 793-94 , 882 A.2d 682 ." (Emphasis added; internal quotation marks omitted.) State v. Delgado , 323 Conn. 801 , 810, 151 A.3d 345 (2016).	2	2
Sullivan v. Stategreen conn · 1983 · cited in 2 Connecticut opinions naming this issue, 2002–2002 2 sentences 2002The court noted that even if the constitutional claim had been colorable, "direct judicial adjudication even of constitutional claims is not warranted when the relief sought by a litigant "might conceivably have been obtained through an alternative [statutory] procedure which [the litigant] has chosen to ignore." La Croix v. Board of Education, 199 Conn. 87 , quoting Sullivan v. State, 189 Conn. 550 , 559 (1983). 2002The court noted that even if the constitutional claim had been colorable, "direct judicial adjudication even of constitutional claims is not warranted when the relief sought by a litigant "might conceivably have been obtained through an alternative [statutory] procedure which [the litigant] has chosen to ignore." La Croix v. Board of Education, 199 Conn. 87 , quoting Sullivan v. State, 189 Conn. 550 559 (1983).	1	2
Ardmare Construction Co. v. Freedmangreen conn · 1983 · cited in 1 Connecticut opinions naming this issue, 2024–2024 2 sentences 2024Compare Spiniello Construction Co. v. Man- chester, 189 Conn. 539, 545 , 456 A.2d 1199 (1983) (unsuc- cessful bidder had standing to challenge award of con- tract because evidence showed that bidding officials favored winning bidder by allowing that bidder to devi- ate from invitation for bids), with Ardmare Construc- tion Co. v. Freedman, 191 Conn. 497, 506 , 467 A.2d 674 (1983) (unsuccessful bidder lacked standing because elements traditionally thought to undermine competi- tive bidding process were absent when official ‘‘did not apply its requirement inconsistently or in a discrimina- tory 2024Compare Spiniello Construction Co. v. Man- chester, 189 Conn. 539, 545 , 456 A.2d 1199 (1983) (unsuc- cessful bidder had standing to challenge award of con- tract because evidence showed that bidding officials favored winning bidder by allowing that bidder to devi- ate from invitation for bids), with Ardmare Construc- tion Co. v. Freedman, 191 Conn. 497, 506 , 467 A.2d 674 (1983) (unsuccessful bidder lacked standing because elements traditionally thought to undermine competi- tive bidding process were absent when official ‘‘did not apply its requirement inconsistently or in a discrimina- tory	1	1
Spiniello Construction Co. v. Town of Manchestergreen conn · 1983 · cited in 1 Connecticut opinions naming this issue, 2024–2024 2 sentences 2024Compare Spiniello Construction Co. v. Man- chester, 189 Conn. 539, 545 , 456 A.2d 1199 (1983) (unsuc- cessful bidder had standing to challenge award of con- tract because evidence showed that bidding officials favored winning bidder by allowing that bidder to devi- ate from invitation for bids), with Ardmare Construc- tion Co. v. Freedman, 191 Conn. 497, 506 , 467 A.2d 674 (1983) (unsuccessful bidder lacked standing because elements traditionally thought to undermine competi- tive bidding process were absent when official ‘‘did not apply its requirement inconsistently or in a discrimina- tory 2024Compare Spiniello Construction Co. v. Man- chester, 189 Conn. 539, 545 , 456 A.2d 1199 (1983) (unsuc- cessful bidder had standing to challenge award of con- tract because evidence showed that bidding officials favored winning bidder by allowing that bidder to devi- ate from invitation for bids), with Ardmare Construc- tion Co. v. Freedman, 191 Conn. 497, 506 , 467 A.2d 674 (1983) (unsuccessful bidder lacked standing because elements traditionally thought to undermine competi- tive bidding process were absent when official ‘‘did not apply its requirement inconsistently or in a discrimina- tory	1	1
Bravo v. United Statesgreen ca11 · 2008 · cited in 1 Connecticut opinions naming this issue, 2012–2012 1 sentence 2012In the present case, both prongs of the test in Connecticut Associated Builders & Contractors speak equally to subject matter jurisdiction, whereas Rozbicki refers to a discussion of the merits following a finding that jurisdiction was lacking. [6] See, e.g., Roth v. Weston, 259 Conn. 202 , 789 A.2d 431 (2002) (announcing two-pronged jurisdictional test and concluding, after thorough analysis, that neither prong was met in that case). [7] See also, e.g., Woods v. Interstate Realty Co., 337 U.S. 535, 537 , 69 S.Ct. 1235 , 93 L.Ed. 1524 (1949) ("where a decision rests on two or more grounds, non	1	1
Nat Resrc Def Cncl v. NRCgreen cadc · 2000 · cited in 1 Connecticut opinions naming this issue, 2012–2012 1 sentence 2012In the present case, both prongs of the test in Connecticut Associated Builders & Contractors speak equally to subject matter jurisdiction, whereas Rozbicki refers to a discussion of the merits following a finding that jurisdiction was lacking. [6] See, e.g., Roth v. Weston, 259 Conn. 202 , 789 A.2d 431 (2002) (announcing two-pronged jurisdictional test and concluding, after thorough analysis, that neither prong was met in that case). [7] See also, e.g., Woods v. Interstate Realty Co., 337 U.S. 535, 537 , 69 S.Ct. 1235 , 93 L.Ed. 1524 (1949) ("where a decision rests on two or more grounds, non	1	1
Woods v. Interstate Realty Co.green scotus · 1949 · cited in 1 Connecticut opinions naming this issue, 2012–2012 2 sentences 2012In the present case, both prongs of the test in Connecticut Associated Builders & Contractors speak equally to subject matter jurisdiction, whereas Rozbicki refers to a discussion of the merits following a finding that jurisdiction was lacking. [6] See, e.g., Roth v. Weston, 259 Conn. 202 , 789 A.2d 431 (2002) (announcing two-pronged jurisdictional test and concluding, after thorough analysis, that neither prong was met in that case). [7] See also, e.g., Woods v. Interstate Realty Co., 337 U.S. 535, 537 , 69 S.Ct. 1235 , 93 L.Ed. 1524 (1949) ("where a decision rests on two or more grounds, non 2012In the present case, both prongs of the test in Connecticut Associated Builders & Contractors speak equally to subject matter jurisdiction, whereas Rozbicki refers to a discussion of the merits following a finding that jurisdiction was lacking. [6] See, e.g., Roth v. Weston, 259 Conn. 202 , 789 A.2d 431 (2002) (announcing two-pronged jurisdictional test and concluding, after thorough analysis, that neither prong was met in that case). [7] See also, e.g., Woods v. Interstate Realty Co., 337 U.S. 535, 537 , 69 S.Ct. 1235 , 93 L.Ed. 1524 (1949) ("where a decision rests on two or more grounds, non	1	1
United States v. Chadrick Evan Fulksgreen ca4 · 2006 · cited in 1 Connecticut opinions naming this issue, 2012–2012 1 sentence 2012In the present case, both prongs of the test in Connecticut Associated Builders & Contractors speak equally to subject matter jurisdiction, whereas Rozbicki refers to a discussion of the merits following a finding that jurisdiction was lacking. [6] See, e.g., Roth v. Weston, 259 Conn. 202 , 789 A.2d 431 (2002) (announcing two-pronged jurisdictional test and concluding, after thorough analysis, that neither prong was met in that case). [7] See also, e.g., Woods v. Interstate Realty Co., 337 U.S. 535, 537 , 69 S.Ct. 1235 , 93 L.Ed. 1524 (1949) ("where a decision rests on two or more grounds, non	1	1
Pyett v. Pennsylvania Building Co.green ca2 · 2007 · cited in 1 Connecticut opinions naming this issue, 2012–2012 1 sentence 2012In the present case, both prongs of the test in Connecticut Associated Builders & Contractors speak equally to subject matter jurisdiction, whereas Rozbicki refers to a discussion of the merits following a finding that jurisdiction was lacking. [6] See, e.g., Roth v. Weston, 259 Conn. 202 , 789 A.2d 431 (2002) (announcing two-pronged jurisdictional test and concluding, after thorough analysis, that neither prong was met in that case). [7] See also, e.g., Woods v. Interstate Realty Co., 337 U.S. 535, 537 , 69 S.Ct. 1235 , 93 L.Ed. 1524 (1949) ("where a decision rests on two or more grounds, non	1	1

Distinguished, questioned or overruled (0)

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

Also cited on this issue (16)

Case	Cited	Years
State v. Delgado green conn · 2016 2 sentences 2018In the absence of a colorable claim requiring correction, the trial court has no jurisdiction to modify the sentence." (Citation omitted; internal 784 quotation marks omitted.) State v. Delgado , supra, 323 Conn. at 810 , 151 A.3d 345 . 2018In the absence of a colorable claim requiring correction, the trial court has no jurisdiction to modify the sentence." (Citation omitted; internal 784 quotation marks omitted.) State v. Delgado , supra, 323 Conn. at 810 , 151 A.3d 345 .	3	2017–2018
United States ex rel. Cody v. Mantech Int'l Corp. green scotus · 2019 2 sentences 2022We have emphasized, however, that ‘‘[t]he jurisdictional and merits inquiries are separate; whether the defendant ultimately succeeds on the merits of his claim does not affect the trial court’s jurisdiction to hear it.’’ State v. Evans, 329 Conn. 770, 784 , 189 A.3d 1184 (2018), cert. denied, U.S , 139 S. Ct. 1304 , 203 L. 2021In the absence of a colorable claim requiring cor- rection, the trial court has no jurisdiction to modify the sentence.’’ (Footnote added; internal quotation marks omitted.) State v. Evans, 329 Conn. 770, 783 , 189 A.3d 1184 (2018), cert. denied, U.S. , 139 S. Ct. 1304 , 203 L.	2	2021–2022
State v. Evans green conn · 2018 2 sentences 2021In the absence of a colorable claim requiring cor- rection, the trial court has no jurisdiction to modify the sentence.’’ (Footnote added; internal quotation marks omitted.) State v. Evans, 329 Conn. 770, 783 , 189 A.3d 1184 (2018), cert. denied, U.S. , 139 S. Ct. 1304 , 203 L. 2021In the absence of a colorable claim requiring cor- rection, the trial court has no jurisdiction to modify the sentence.’’ (Footnote added; internal quotation marks omitted.) State v. Evans, 329 Conn. 770, 783 , 189 A.3d 1184 (2018), cert. denied, U.S. , 139 S. Ct. 1304 , 203 L.	2	2021–2022
Morris County Bd. of Chosen Freeholders v. Freedom From Religion Foundation green · 2019 2 sentences 2022We have emphasized, however, that ‘‘[t]he jurisdictional and merits inquiries are separate; whether the defendant ultimately succeeds on the merits of his claim does not affect the trial court’s jurisdiction to hear it.’’ State v. Evans, 329 Conn. 770, 784 , 189 A.3d 1184 (2018), cert. denied, U.S , 139 S. Ct. 1304 , 203 L. 2021In the absence of a colorable claim requiring cor- rection, the trial court has no jurisdiction to modify the sentence.’’ (Footnote added; internal quotation marks omitted.) State v. Evans, 329 Conn. 770, 783 , 189 A.3d 1184 (2018), cert. denied, U.S. , 139 S. Ct. 1304 , 203 L.	2	2021–2022
Halladay v. Commissioner of Correction green conn · 2021 1 sentence 2025Having to participate in an agency proceeding, in the absence of a colorable claim of immu- nity, is ‘‘an indirect result of an agency proceeding and 18 The city also cites Shay v. Rossi, 253 Conn. 134, 165 , 749 A.2d 1147 (2000), and Halladay v. Commissioner of Correction, 340 Conn. 52, 62 , 262 A.3d 823 (2021), both of which apply our final judgment doctrine under State v. Curcio, 191 Conn. 27, 31 , 463 A.2d 566 (1983), to trial court proceedings.	1	2025–2025
Shay v. Rossi green conn · 2000 2 sentences 2025Having to participate in an agency proceeding, in the absence of a colorable claim of immu- nity, is ‘‘an indirect result of an agency proceeding and 18 The city also cites Shay v. Rossi, 253 Conn. 134, 165 , 749 A.2d 1147 (2000), and Halladay v. Commissioner of Correction, 340 Conn. 52, 62 , 262 A.3d 823 (2021), both of which apply our final judgment doctrine under State v. Curcio, 191 Conn. 27, 31 , 463 A.2d 566 (1983), to trial court proceedings. 2025Having to participate in an agency proceeding, in the absence of a colorable claim of immu- nity, is ‘‘an indirect result of an agency proceeding and 18 The city also cites Shay v. Rossi, 253 Conn. 134, 165 , 749 A.2d 1147 (2000), and Halladay v. Commissioner of Correction, 340 Conn. 52, 62 , 262 A.3d 823 (2021), both of which apply our final judgment doctrine under State v. Curcio, 191 Conn. 27, 31 , 463 A.2d 566 (1983), to trial court proceedings.	1	2025–2025
State v. Curcio green conn · 1983 2 sentences 2025Having to participate in an agency proceeding, in the absence of a colorable claim of immu- nity, is ‘‘an indirect result of an agency proceeding and 18 The city also cites Shay v. Rossi, 253 Conn. 134, 165 , 749 A.2d 1147 (2000), and Halladay v. Commissioner of Correction, 340 Conn. 52, 62 , 262 A.3d 823 (2021), both of which apply our final judgment doctrine under State v. Curcio, 191 Conn. 27, 31 , 463 A.2d 566 (1983), to trial court proceedings. 2025Having to participate in an agency proceeding, in the absence of a colorable claim of immu- nity, is ‘‘an indirect result of an agency proceeding and 18 The city also cites Shay v. Rossi, 253 Conn. 134, 165 , 749 A.2d 1147 (2000), and Halladay v. Commissioner of Correction, 340 Conn. 52, 62 , 262 A.3d 823 (2021), both of which apply our final judgment doctrine under State v. Curcio, 191 Conn. 27, 31 , 463 A.2d 566 (1983), to trial court proceedings.	1	2025–2025
Lawrence Brunoli, Inc. v. Town of Branford green conn · 1999 2 sentences 2024In addition, ‘‘an unsuccessful bidder to a municipal contract has no standing to assert a cause of action for money damages for failure of the municipality to follow its competitive bidding laws, regardless of whether the plaintiff alleges fraud, corruption or favoritism.’’ Law- rence Brunoli, Inc. v. Branford, 247 Conn. 407, 411 , 722 A.2d 271 (1999).14 Thus, in the absence of a colorable claim of fraud, corruption or other acts undermining the integrity of the bidding process, an unsuccessful bidder lacks standing to challenge the award of a public contract. 2024In addition, ‘‘an unsuccessful bidder to a municipal contract has no standing to assert a cause of action for money damages for failure of the municipality to follow its competitive bidding laws, regardless of whether the plaintiff alleges fraud, corruption or favoritism.’’ Law- rence Brunoli, Inc. v. Branford, 247 Conn. 407, 411 , 722 A.2d 271 (1999).14 Thus, in the absence of a colorable claim of fraud, corruption or other acts undermining the integrity of the bidding process, an unsuccessful bidder lacks standing to challenge the award of a public contract.	1	2024–2024
State v. Myers neutral conn · 2022 1 sentence 2022In the absence of a colorable claim requiring correction, the trial court has no jurisdiction . . . .’’ (Footnote omitted; internal quotation marks omitted.) State v. Myers, 343 Conn. 447, 459 , 274 A.3d 100 (2022). ‘‘[T]o raise a colorable claim within the scope of Practice Book § 43-22, the legal claim and factual allegations must demonstrate a possibility that the defendant’s claim challenges his or her sentence or sentencing proceedings, not the under- lying conviction.	1	2022–2022
Asset Acceptance, LLC v. Moberly green ky · 2007 1 sentence 2020Under the exception, ‘‘the only question on appeal is the jurisdictional one’’; in the absence of a colorable challenge to the trial court’s jurisdiction, ‘‘the appellate court’s own jurisdic- tion fails, and the appeal must be dismissed.’’ Asset Acceptance, LLC v. Moberly, supra, 333 .	1	2020–2020
State v. Jason B. neutral connappct · 2017 2 sentences 2019In the absence of a colorable claim requiring correction, the trial court has no jurisdiction to modify the sentence." (Citations omitted; emphasis omitted; internal quotation marks omitted.) State v. Jason B. , 176 Conn. App. 236 , 243-44, 170 A.3d 139 (2017). 2019In the absence of a colorable claim requiring correction, the trial court has no jurisdiction to modify the sentence." (Citations omitted; emphasis omitted; internal quotation marks omitted.) State v. Jason B. , 176 Conn. App. 236 , 243-44, 170 A.3d 139 (2017).	1	2019–2019
Statewide Grievance Committee v. Rozbicki green conn · 1989 2 sentences 2012But under the present constitutional division of power, in the absence of a colorable claim of procedural corruption, these are judgments to be made by the legislature, not by this court. [5] For this reason, I am not swayed by the majority's citation to Statewide Grievance Committee v. Rozbicki, 211 Conn. 232 , 558 A.2d 986 (1989). 2012But under the present constitutional division of power, in the absence of a colorable claim of procedural corruption, these are judgments to be made by the legislature, not by this court. [5] For this reason, I am not swayed by the majority's citation to Statewide Grievance Committee v. Rozbicki, 211 Conn. 232 , 558 A.2d 986 (1989).	1	2012–2012
Roth v. Weston green conn · 2002 2 sentences 2012In the present case, both prongs of the test in Connecticut Associated Builders & Contractors speak equally to subject matter jurisdiction, whereas Rozbicki refers to a discussion of the merits following a finding that jurisdiction was lacking. [6] See, e.g., Roth v. Weston, 259 Conn. 202 , 789 A.2d 431 (2002) (announcing two-pronged jurisdictional test and concluding, after thorough analysis, that neither prong was met in that case). [7] See also, e.g., Woods v. Interstate Realty Co., 337 U.S. 535, 537 , 69 S.Ct. 1235 , 93 L.Ed. 1524 (1949) ("where a decision rests on two or more grounds, non 2012In the present case, both prongs of the test in Connecticut Associated Builders & Contractors speak equally to subject matter jurisdiction, whereas Rozbicki refers to a discussion of the merits following a finding that jurisdiction was lacking. [6] See, e.g., Roth v. Weston, 259 Conn. 202 , 789 A.2d 431 (2002) (announcing two-pronged jurisdictional test and concluding, after thorough analysis, that neither prong was met in that case). [7] See also, e.g., Woods v. Interstate Realty Co., 337 U.S. 535, 537 , 69 S.Ct. 1235 , 93 L.Ed. 1524 (1949) ("where a decision rests on two or more grounds, non	1	2012–2012
United States v. Title Insurance & Trust Co. green scotus · 1924 2 sentences 2012In the present case, both prongs of the test in Connecticut Associated Builders & Contractors speak equally to subject matter jurisdiction, whereas Rozbicki refers to a discussion of the merits following a finding that jurisdiction was lacking. [6] See, e.g., Roth v. Weston, 259 Conn. 202 , 789 A.2d 431 (2002) (announcing two-pronged jurisdictional test and concluding, after thorough analysis, that neither prong was met in that case). [7] See also, e.g., Woods v. Interstate Realty Co., 337 U.S. 535, 537 , 69 S.Ct. 1235 , 93 L.Ed. 1524 (1949) ("where a decision rests on two or more grounds, non 2012In the present case, both prongs of the test in Connecticut Associated Builders & Contractors speak equally to subject matter jurisdiction, whereas Rozbicki refers to a discussion of the merits following a finding that jurisdiction was lacking. [6] See, e.g., Roth v. Weston, 259 Conn. 202 , 789 A.2d 431 (2002) (announcing two-pronged jurisdictional test and concluding, after thorough analysis, that neither prong was met in that case). [7] See also, e.g., Woods v. Interstate Realty Co., 337 U.S. 535, 537 , 69 S.Ct. 1235 , 93 L.Ed. 1524 (1949) ("where a decision rests on two or more grounds, non	1	2012–2012
United States v. Arlene Elizabeth Rohde green ca10 · 1998 1 sentence 2012In the present case, both prongs of the test in Connecticut Associated Builders & Contractors speak equally to subject matter jurisdiction, whereas Rozbicki refers to a discussion of the merits following a finding that jurisdiction was lacking. [6] See, e.g., Roth v. Weston, 259 Conn. 202 , 789 A.2d 431 (2002) (announcing two-pronged jurisdictional test and concluding, after thorough analysis, that neither prong was met in that case). [7] See also, e.g., Woods v. Interstate Realty Co., 337 U.S. 535, 537 , 69 S.Ct. 1235 , 93 L.Ed. 1524 (1949) ("where a decision rests on two or more grounds, non	1	2012–2012
United States v. Bueno green ca5 · 2009 1 sentence 2012In the present case, both prongs of the test in Connecticut Associated Builders & Contractors speak equally to subject matter jurisdiction, whereas Rozbicki refers to a discussion of the merits following a finding that jurisdiction was lacking. [6] See, e.g., Roth v. Weston, 259 Conn. 202 , 789 A.2d 431 (2002) (announcing two-pronged jurisdictional test and concluding, after thorough analysis, that neither prong was met in that case). [7] See also, e.g., Woods v. Interstate Realty Co., 337 U.S. 535, 537 , 69 S.Ct. 1235 , 93 L.Ed. 1524 (1949) ("where a decision rests on two or more grounds, non	1	2012–2012

Statutes the citing opinions construe

CT § Conn. Gen. Stat. § 43-22 (8) CT § Conn. Gen. Stat. § 51-199 (4) CT § Conn. Gen. Stat. § 54-125a (4) CT § Conn. Gen. Stat. § 53a-54a (3) CT § Conn. Gen. Stat. § 54-91g (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

CT 14 (2002–2025) NJ 3 (2017–2018)

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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