signature requirement in Connecticut

2004Notably, although § 8-5 (1) of the Connecticut Code of Evidence lists only written statements, the commentary expressly recognizes that although the “post-Whelan developments were not expressly incorporated into the language of Section 8-5 (1) . . . [the] post-Whelan developments nevertheless are considered to be an integral part of this rule.” The commentary also cites State v. Woodson, 227 Conn. 1, 21 , 629 A.2d 386 (1993), which dispenses with the declarant’s signature as a requirement when the statement is tape recorded.

2004Notably, although § 8-5 (1) of the Connecticut Code of Evidence lists only written statements, the commentary expressly recognizes that although the “post-Whelan developments were not expressly incorporated into the language of Section 8-5 (1) . . . [the] post-Whelan developments nevertheless are considered to be an integral part of this rule.” The commentary also cites State v. Woodson, 227 Conn. 1, 21 , 629 A.2d 386 (1993), which dispenses with the declarant’s signature as a requirement when the statement is tape recorded.

2022See Blake v. Meyer, 145 Conn. 612, 616 , 145 A.2d 584 (1958) (‘‘[i]t is clear that the provision under consideration is mandatory, not merely directory, even in the absence of prohibitory or negative language’’).

2022See Blake v. Meyer, 145 Conn. 612, 616 , 145 A.2d 584 (1958) (‘‘[i]t is clear that the provision under consideration is mandatory, not merely directory, even in the absence of prohibitory or negative language’’).

2012Conversely, in Ardmare Construction Co. v. Freedman, 191 Conn. 497, 499, 505 , 467 A.2d 674 (1983), this court concluded that the plaintiff lacked standing to challenge the rejection of its lowest bid for failure to include a handwritten signature on the bid document because the signature requirement— however arbitrary or detrimental to the plaintiff—was uniformly applied and there was no showing of fraud or favoritism.

2012Conversely, in Ardmare Construction Co. v. Freedman, 191 Conn. 497, 499, 505 , 467 A.2d 674 (1983), this court concluded that the plaintiff lacked standing to challenge the rejection of its lowest bid for failure to include a handwritten signature on the bid document because the signature requirement— however arbitrary or detrimental to the plaintiff—was uniformly applied and there was no showing of fraud or favoritism.

2007See State v. Greene, supra, 209 Conn. 465 -66 (concluding that evidence was cross admissible because factual similarities compare favorably to Mandrell and State v. Braman, 191 Conn. 670, 678 , 469 A.2d 760 [1983]); State v. Jones, supra, 205 Conn. 661 (applying signature test to assess admissibility of evidence of uncharged misconduct evidence and citing, inter alia, Mandrell and State v. Crosby, 196 Conn. 185, 191 , 491 A.2d 1092 [1985] [identity case]); but see State v. Braman, supra, 677-78, 681 (using signature test to assess admissibility of evidence of uncharged misconduct offered to pr

2007See State v. Greene, supra, 209 Conn. 465 -66 (concluding that evidence was cross admissible because factual similarities compare favorably to Mandrell and State v. Braman, 191 Conn. 670, 678 , 469 A.2d 760 [1983]); State v. Jones, supra, 205 Conn. 661 (applying signature test to assess admissibility of evidence of uncharged misconduct evidence and citing, inter alia, Mandrell and State v. Crosby, 196 Conn. 185, 191 , 491 A.2d 1092 [1985] [identity case]); but see State v. Braman, supra, 677-78, 681 (using signature test to assess admissibility of evidence of uncharged misconduct offered to pr

2007See, e.g., State v. Payne, 219 Conn. 93, 100 , 591 A.2d 1246 (1991); State v. Sierra, 213 Conn. 422, 430 , 568 A.2d 448 (1990). *352 The signature test is pertinent to the common scheme or plan inquiry, however, when the state seeks to establish the existence of an overall plan in the defendant’s mind based solely on the similarities shared by the charged and uncharged crimes.

2007See, e.g., State v. Payne, 219 Conn. 93, 100 , 591 A.2d 1246 (1991); State v. Sierra, 213 Conn. 422, 430 , 568 A.2d 448 (1990). *352 The signature test is pertinent to the common scheme or plan inquiry, however, when the state seeks to establish the existence of an overall plan in the defendant’s mind based solely on the similarities shared by the charged and uncharged crimes.

2006Co. v. Bryant, 245 Conn. 710, 725 , 714 A.2d 1209 (1998) (“the legislative objective underlying the signature requirement of [the statute is] to promote informed decision-making by purchasers of uninsured motorist coverage”).

2006Co. v. Bryant, 245 Conn. 710, 725 , 714 A.2d 1209 (1998) (“the legislative objective underlying the signature requirement of [the statute is] to promote informed decision-making by purchasers of uninsured motorist coverage”).

2001See State v. Hermann, 38 Conn. App. 56, 67-68 , 658 A.2d 148 , cert. denied, 235 Conn. 903 , 665 A.2d 904 (1995); see also State v. Woodson, 227 Conn. 1, 22 , 629 A.2d 386 (1993).

2001See State v. Hermann, 38 Conn. App. 56, 67-68 , 658 A.2d 148 , cert. denied, 235 Conn. 903 , 665 A.2d 904 (1995); see also State v. Woodson, 227 Conn. 1, 22 , 629 A.2d 386 (1993).

2001See State v. Hermann, 38 Conn. App. 56, 67-68 , 658 A.2d 148 , cert. denied, 235 Conn. 903 , 665 A.2d 904 (1995); see also State v. Woodson, 227 Conn. 1, 22 , 629 A.2d 386 (1993).

2001See State v. Hermann, 38 Conn. App. 56, 67-68 , 658 A.2d 148 , cert. denied, 235 Conn. 903 , 665 A.2d 904 (1995); see also State v. Woodson, 227 Conn. 1, 22 , 629 A.2d 386 (1993).

2001See Merrill Lynch, Pierce, Fenner Smith, Inc. v. Cole , 189 Conn. 518 , 532 , 457 A.2d 656 (1983) ("a letterhead or billhead satisfies the signature requirement.") The form, therefore, constitutes prima facie evidence that the RTC intentionally discharged the debt by a signed writing.

2001See Merrill Lynch, Pierce, Fenner Smith, Inc. v. Cole , 189 Conn. 518 , 532 , 457 A.2d 656 (1983) ("a letterhead or billhead satisfies the signature requirement.") The form, therefore, constitutes prima facie evidence that the RTC intentionally discharged the debt by a signed writing.

1998See Woodruff & Son v. Rhoton, 251 Iowa 550, 556 , 101 N.W.2d 720 (1960); Parma Tile Mosaic & Marble Co. v. Estate of Short, 87 N.Y.2d 524, 527 , 663 N.E.2d 633 , 640 N.Y.S.2d 477 (1996); Mesibov, Glinert & Levy, Inc. v. Cohen Bros.

1998See Woodruff & Son v. Rhoton, 251 Iowa 550, 556 , 101 N.W.2d 720 (1960); Parma Tile Mosaic & Marble Co. v. Estate of Short, 87 N.Y.2d 524, 527 , 663 N.E.2d 633 , 640 N.Y.S.2d 477 (1996); Mesibov, Glinert & Levy, Inc. v. Cohen Bros.

1996Co., supra, 514 U.S. 656 -57, the court in O’Shea v. First Manhattan Co. Thrift Plan & Trust, 55 F.3d 109, 113 (2d Cir. 1995), focused on Congress’ goal in enacting ERISA, namely, “to ensure that plans and plan sponsors would be subject to a uniform body of benefits law . . . [and to prevent] the potential for conflict in substantive law . . . requiring the tailoring of plans and employer conduct to the peculiarities of the law of each jurisdiction.” (Emphasis added; internal quotation marks omitted.) The court determined that a New York statute requiring death beneficiary designations to be i

1996To impose such a requirement in New York, but not elsewhere, would frustrate ERISA’s goal of establishing a unified national system to safeguard retirement benefits.” Id., 114 ; see Greenblatt v. Delta Plumbing & Heating Corp., 68 F.3d 561, 574 (2d Cir. 1995) (primary purpose of ERISA preemption is “ ‘to avoid a multiplicity of regulation in order to permit the nationally uniform administration of employee benefit plans’ ”).

1996To impose such a requirement in New York, but not elsewhere, would frustrate ERISA’s goal of establishing a unified national system to safeguard retirement benefits.” Id., 114 ; see Greenblatt v. Delta Plumbing & Heating Corp., 68 F.3d 561, 574 (2d Cir. 1995) (primary purpose of ERISA preemption is “ ‘to avoid a multiplicity of regulation in order to permit the nationally uniform administration of employee benefit plans’ ”).

1983Shpilberg v. Merrill Lynch, Pierce, Fenner & Smith, Inc., 535 S.W.2d 227, 229 (Ky. 1976). 8 The confirmation slip so signed was sufficient to bind the broker.