absence of a colorable claim (Connecticut) · Go Syfert
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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 (10)

CaseFollowedCited
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).

22
State v. Wardgreen
conn · 2021 · cited in 2 Connecticut opinions naming this issue, 2022–2022
2 sentences

2022The ultimate legal correctness of the claim is not relevant to our jurisdictional analysis.’’ State v. Ward, 341 Conn. 142 , 153, 266 A.3d 807 (2021).3 ‘‘[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.’’ (Internal quotation marks omitted.) State v. Myers, supra, 459 .

2022The ultimate legal correctness of the claim is not relevant to our jurisdictional analysis.’’ State v. Ward, 341 Conn. 142 , 153, 266 A.3d 807 (2021).3 ‘‘[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.’’ (Internal quotation marks omitted.) State v. Myers, supra, 459 .

12
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).

12
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. Manchester, 189 Conn. 539, 545 , 456 A.2d 1199 (1983) (unsuccessful bidder had standing to challenge award of contract because evidence showed that bidding officials favored winning bidder by allowing that bidder to deviate from invitation for bids), with Ardmare Construction Co. v. Freedman, 191 Conn. 497, 506 , 467 A.2d 674 (1983) (unsuccessful bidder lacked standing because elements traditionally thought to undermine competitive bidding process were absent when official ‘‘did not apply its requirement inconsistently or in a discriminatory fashion’’).

2024Compare Spiniello Construction Co. v. Manchester, 189 Conn. 539, 545 , 456 A.2d 1199 (1983) (unsuccessful bidder had standing to challenge award of contract because evidence showed that bidding officials favored winning bidder by allowing that bidder to deviate from invitation for bids), with Ardmare Construction Co. v. Freedman, 191 Conn. 497, 506 , 467 A.2d 674 (1983) (unsuccessful bidder lacked standing because elements traditionally thought to undermine competitive bidding process were absent when official ‘‘did not apply its requirement inconsistently or in a discriminatory fashion’’).

11
Ardmare Construction Co. v. Freedmangreen
conn · 1983 · cited in 1 Connecticut opinions naming this issue, 2024–2024
2 sentences

2024Compare Spiniello Construction Co. v. Manchester, 189 Conn. 539, 545 , 456 A.2d 1199 (1983) (unsuccessful bidder had standing to challenge award of contract because evidence showed that bidding officials favored winning bidder by allowing that bidder to deviate from invitation for bids), with Ardmare Construction Co. v. Freedman, 191 Conn. 497, 506 , 467 A.2d 674 (1983) (unsuccessful bidder lacked standing because elements traditionally thought to undermine competitive bidding process were absent when official ‘‘did not apply its requirement inconsistently or in a discriminatory fashion’’).

2024Compare Spiniello Construction Co. v. Manchester, 189 Conn. 539, 545 , 456 A.2d 1199 (1983) (unsuccessful bidder had standing to challenge award of contract because evidence showed that bidding officials favored winning bidder by allowing that bidder to deviate from invitation for bids), with Ardmare Construction Co. v. Freedman, 191 Conn. 497, 506 , 467 A.2d 674 (1983) (unsuccessful bidder lacked standing because elements traditionally thought to undermine competitive bidding process were absent when official ‘‘did not apply its requirement inconsistently or in a discriminatory fashion’’).

11
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

11
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

11
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

11
Pyett v. Pennsylvania Building Co.red
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

11
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

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 (16)

CaseCitedYears
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 .

32017–2018
State v. Evans green
conn · 2018
2 sentences

2021In the absence of a colorable claim requiring correction, 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. Ed. 2d 425 (2019). ‘‘A colorable claim is one that is superficially well founded but that may ultimately be deemed invalid. . . .

2021In the absence of a colorable claim requiring correction, 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. Ed. 2d 425 (2019). ‘‘A colorable claim is one that is superficially well founded but that may ultimately be deemed invalid. . . .

22021–2022
Evans v. Connecticut green
scotus · 2019
2 sentences

2021In the absence of a colorable claim requiring correction, 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. Ed. 2d 425 (2019). ‘‘A colorable claim is one that is superficially well founded but that may ultimately be deemed invalid. . . .

2021In the absence of a colorable claim requiring correction, 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. Ed. 2d 425 (2019). ‘‘A colorable claim is one that is superficially well founded but that may ultimately be deemed invalid. . . .

22021–2022
State v. Curcio green
conn · 1983
2 sentences

2025Having to participate in an agency proceeding, in the absence of a colorable claim of immunity, 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 immunity, 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.

12025–2025
Shay v. Rossi red
conn · 2000
2 sentences

2025Having to participate in an agency proceeding, in the absence of a colorable claim of immunity, 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 immunity, 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.

12025–2025
Halladay v. Commissioner of Correction green
conn · 2021
2 sentences

2025Having to participate in an agency proceeding, in the absence of a colorable claim of immunity, 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 immunity, 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.

12025–2025
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.’’ Lawrence 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.’’ Lawrence 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.

12024–2024
State v. Myers neutral
conn · 2022
2 sentences

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 underlying conviction.

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 underlying conviction.

12022–2022
State v. McCleese green
conn · 2019
1 sentence

2022In the absence of a colorable claim requiring correction, the trial court has no jurisdiction . . . .’’ (Citations omitted; footnote in original; internal quotation marks omitted.) State v. McCleese, 333 Conn. 378 , 386, 215 A.3d 1154 (2019).

12022–2022
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 jurisdiction fails, and the appeal must be dismissed.’’ Asset Acceptance, LLC v. Moberly, supra, 333 .

12020–2020
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).

12019–2019
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

12012–2012
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

12012–2012
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

12012–2012
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).

12012–2012
Roth v. Weston yellow
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

12012–2012

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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