vicarious liability doctrine (Connecticut) · Go Syfert
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vicarious liability doctrine in Connecticut

13 Connecticut opinions name it 3 courts 1999–2024 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 (3)

CaseFollowedCited
Curry v. District of Columbiagreen
cadc · 1999 · cited in 2 Connecticut opinions naming this issue, 2024–2024
2 sentences

2024See Vance v. Ball State University, supra, 570 U.S. 448–49. ‘‘[Although] the reasonableness of an employer’s response to . . . harassment is at issue under both standards, the plaintiff must clear a higher hurdle under the negligence standard [applicable to harassment by coworkers], where she bears the bur- den of establishing her employer’s negligence, than 0, 0 CONNECTICUT LAW JOURNAL Page 11 0 Conn. 1 ,0 13 O’Reggio v. Commission on Human Rights & Opportunities under the vicarious liability standard [applicable to harassment by supervisors], where the burden shifts to the employer to prove

2024See Vance v. Ball State University, supra, 570 U.S. 448–49. ‘‘[Although] the reasonableness of an employer’s response to . . . harassment is at issue under both standards, the plaintiff must clear a higher hurdle under the negligence standard [applicable to harassment by coworkers], where she bears the bur- den of establishing her employer’s negligence, than under the vicarious liability standard [applicable to harassment by supervisors], where the burden shifts to the employer to prove its own reasonableness and the plaintiff’s negligence.’’ Curry v. District of Columbia, 195 F.3d 654, 660 (D

22
Pinkerton v. United Statesgreen
scotus · 1946 · cited in 3 Connecticut opinions naming this issue, 2009–2017
2 sentences

2017In fact, he did place his penis ... into her vagina briefly." 3 See Pinkerton v. United States , 328 U.S. 640 , 647-48, 66 S.Ct. 1180 , 90 L.Ed. 1489 (1946). 4 In the petitioner's direct appeal, our Supreme Court commented on this aspect of the court's instructions as follows: "During the charging conference, the [petitioner], the state and the trial court discussed that, specifically as to count eight, the [petitioner] was charged and could be found liable as a principal, as an accessory, or under the Pinkerton doctrine of vicarious liability. ...

2017In fact, he did place his penis ... into her vagina briefly." 3 See Pinkerton v. United States , 328 U.S. 640 , 647-48, 66 S.Ct. 1180 , 90 L.Ed. 1489 (1946). 4 In the petitioner's direct appeal, our Supreme Court commented on this aspect of the court's instructions as follows: "During the charging conference, the [petitioner], the state and the trial court discussed that, specifically as to count eight, the [petitioner] was charged and could be found liable as a principal, as an accessory, or under the Pinkerton doctrine of vicarious liability. ...

13
United States v. Franklin Delano Gipsongreen
ca5 · 1977 · cited in 1 Connecticut opinions naming this issue, 2006–2006
1 sentence

2006That is, one with which you all agree.” 17 The defendant argued before the trial court that this court’s decision in State v. Coltherst, 263 Conn. 478 , 820 A.2d 1024 (2003), “does not support *608 the proposition that the court can instruct a lack of unanimity on those three different forms of liability.” The trial court, however, agreed with the state’s position that its charge was proper in light of this court’s decision in State v. Correa, supra, 241 Conn. 322 , and ruled that the instruction would remain as read because “coconspirator liability is a vicarious liability principle just like

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 (20)

CaseCitedYears
Alvarez v. New Haven Register, Inc. green
conn · 1999
2 sentences

2001In Alvarez v. New Haven Register, Inc ., 249 Conn. 709 , 735 A.2d 306 (1999), the court recognized "that [a master and a servant] are both undoubtedly tortfeasors, and that the injured plaintiff may look for reparation from either the agent or the principal".

2001The court further held that "aside from the relationship between the parties creating the doctrine of vicarious liability, the principal is not a tortfeasor in the true sense of the word because he is not independently liable based upon his own independent actionable fault." Id., 720-21 .

32001–2001
Shafer v. Suburban Newspapers of Greater St. Louis, Inc. green
scotus · 2000
2 sentences

2024Cir. 1999), cert. denied, 530 U.S. 1215 , 120 S. Ct. 2219 , 147 L.

2024Cir. 1999), cert. denied, 530 U.S. 1215 , 120 S. Ct. 2219 , 147 L.

22024–2024
Sinclair v. Ward neutral
scotus · 2000
2 sentences

2024Cir. 1999), cert. denied, 530 U.S. 1215 , 120 S. Ct. 2219 , 147 L.

2024Cir. 1999), cert. denied, 530 U.S. 1215 , 120 S. Ct. 2219 , 147 L.

22024–2024
District of Columbia v. Curry green
scotus · 2000
2 sentences

2024Cir. 1999), cert. denied, 530 U.S. 1215 , 120 S. Ct. 2219 , 147 L.

2024Cir. 1999), cert. denied, 530 U.S. 1215 , 120 S. Ct. 2219 , 147 L.

22024–2024
State v. Walton green
conn · 1993
2 sentences

2012“Pursuant to the Pinkerton doctrine of vicarious liability, articulated by the United States Supreme Court in Pinkerton . . . and expressly adopted by our Supreme Court in State v. Walton, 227 Conn. 32 , 630 A.2d 990 (1993), a conspirator may be held liable for criminal offenses committed by a coconspirator that are within the scope of the conspiracy, are in furtherance of it, and are reasonably foreseeable as a necessary or natural consequence of the conspiracy.” (Internal quotation marks omitted.) State v. LaFountain, 127 Conn. App. 819, 827 , 16 A.3d 761 , cert. denied, 301 Conn. 921 , 22 A

2012“Pursuant to the Pinkerton doctrine of vicarious liability, articulated by the United States Supreme Court in Pinkerton . . . and expressly adopted by our Supreme Court in State v. Walton, 227 Conn. 32 , 630 A.2d 990 (1993), a conspirator may be held liable for criminal offenses committed by a coconspirator that are within the scope of the conspiracy, are in furtherance of it, and are reasonably foreseeable as a necessary or natural consequence of the conspiracy.” (Internal quotation marks omitted.) State v. LaFountain, 127 Conn. App. 819, 827 , 16 A.3d 761 , cert. denied, 301 Conn. 921 , 22 A

22011–2012
State v. Coltherst green
conn · 2003
2 sentences

2006That is, one with which you all agree.” 17 The defendant argued before the trial court that this court’s decision in State v. Coltherst, 263 Conn. 478 , 820 A.2d 1024 (2003), “does not support *608 the proposition that the court can instruct a lack of unanimity on those three different forms of liability.” The trial court, however, agreed with the state’s position that its charge was proper in light of this court’s decision in State v. Correa, supra, 241 Conn. 322 , and ruled that the instruction would remain as read because “coconspirator liability is a vicarious liability principle just like

2006That is, one with which you all agree.” 17 The defendant argued before the trial court that this court’s decision in State v. Coltherst, 263 Conn. 478 , 820 A.2d 1024 (2003), “does not support *608 the proposition that the court can instruct a lack of unanimity on those three different forms of liability.” The trial court, however, agreed with the state’s position that its charge was proper in light of this court’s decision in State v. Correa, supra, 241 Conn. 322 , and ruled that the instruction would remain as read because “coconspirator liability is a vicarious liability principle just like

22006–2011
State v. Hampton green
conn · 2009
1 sentence

2016In Hampton, the parties, during a charging conference, discussed with the trial court that, on count eight of the information, the defendant ‘‘could be found liable as a principal, as an accessory, or under the Pinkerton doctrine of vicarious liability.’’ Id.

12016–2016
State v. LaFountain neutral
connappct · 2011
2 sentences

2012“Pursuant to the Pinkerton doctrine of vicarious liability, articulated by the United States Supreme Court in Pinkerton . . . and expressly adopted by our Supreme Court in State v. Walton, 227 Conn. 32 , 630 A.2d 990 (1993), a conspirator may be held liable for criminal offenses committed by a coconspirator that are within the scope of the conspiracy, are in furtherance of it, and are reasonably foreseeable as a necessary or natural consequence of the conspiracy.” (Internal quotation marks omitted.) State v. LaFountain, 127 Conn. App. 819, 827 , 16 A.3d 761 , cert. denied, 301 Conn. 921 , 22 A

2012“Pursuant to the Pinkerton doctrine of vicarious liability, articulated by the United States Supreme Court in Pinkerton . . . and expressly adopted by our Supreme Court in State v. Walton, 227 Conn. 32 , 630 A.2d 990 (1993), a conspirator may be held liable for criminal offenses committed by a coconspirator that are within the scope of the conspiracy, are in furtherance of it, and are reasonably foreseeable as a necessary or natural consequence of the conspiracy.” (Internal quotation marks omitted.) State v. LaFountain, 127 Conn. App. 819, 827 , 16 A.3d 761 , cert. denied, 301 Conn. 921 , 22 A

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

2012“Pursuant to the Pinkerton doctrine of vicarious liability, articulated by the United States Supreme Court in Pinkerton . . . and expressly adopted by our Supreme Court in State v. Walton, 227 Conn. 32 , 630 A.2d 990 (1993), a conspirator may be held liable for criminal offenses committed by a coconspirator that are within the scope of the conspiracy, are in furtherance of it, and are reasonably foreseeable as a necessary or natural consequence of the conspiracy.” (Internal quotation marks omitted.) State v. LaFountain, 127 Conn. App. 819, 827 , 16 A.3d 761 , cert. denied, 301 Conn. 921 , 22 A

2012“Pursuant to the Pinkerton doctrine of vicarious liability, articulated by the United States Supreme Court in Pinkerton . . . and expressly adopted by our Supreme Court in State v. Walton, 227 Conn. 32 , 630 A.2d 990 (1993), a conspirator may be held liable for criminal offenses committed by a coconspirator that are within the scope of the conspiracy, are in furtherance of it, and are reasonably foreseeable as a necessary or natural consequence of the conspiracy.” (Internal quotation marks omitted.) State v. LaFountain, 127 Conn. App. 819, 827 , 16 A.3d 761 , cert. denied, 301 Conn. 921 , 22 A

12012–2012
State v. Holmes green
connappct · 2003
2 sentences

2011Section 53a-59 (a) provides in relevant part: “A person is guilty of assault in the first degree when ... (5) with intent to cause physical injury to another person, he causes such injury to such person or to a third person by means of the discharge of a firearm.” “Assault in the first degree is a specific intent crime.” State v. Holmes, 75 Conn. App. 721, 736 , 817 A.2d 689 , cert, denied, 264 Conn. 903 , 823 A.2d 1222 (2003).

2011Section 53a-59 (a) provides in relevant part: “A person is guilty of assault in the first degree when ... (5) with intent to cause physical injury to another person, he causes such injury to such person or to a third person by means of the discharge of a firearm.” “Assault in the first degree is a specific intent crime.” State v. Holmes, 75 Conn. App. 721, 736 , 817 A.2d 689 , cert, denied, 264 Conn. 903 , 823 A.2d 1222 (2003).

12011–2011
State v. Widlak green
conn · 2003
1 sentence

2011Section 53a-59 (a) provides in relevant part: “A person is guilty of assault in the first degree when ... (5) with intent to cause physical injury to another person, he causes such injury to such person or to a third person by means of the discharge of a firearm.” “Assault in the first degree is a specific intent crime.” State v. Holmes, 75 Conn. App. 721, 736 , 817 A.2d 689 , cert, denied, 264 Conn. 903 , 823 A.2d 1222 (2003).

12011–2011
State v. Holmes green
conn · 2003
1 sentence

2011Section 53a-59 (a) provides in relevant part: “A person is guilty of assault in the first degree when ... (5) with intent to cause physical injury to another person, he causes such injury to such person or to a third person by means of the discharge of a firearm.” “Assault in the first degree is a specific intent crime.” State v. Holmes, 75 Conn. App. 721, 736 , 817 A.2d 689 , cert, denied, 264 Conn. 903 , 823 A.2d 1222 (2003).

12011–2011
State v. Martinez green
conn · 2006
2 sentences

2011Accordingly, for the defendant to be convicted of the crime of assault in the first degree under the Pinkerton doctrine of vicarious liability, the state was required to prove, beyond a reasonable doubt, that the crime of assault in the first degree was committed by the defendant’s coconspirator, Bodamer. 3 See State v. Martinez, 278 Conn. 598, 618 , 900 A.2d 485 (2006) (“under the Pinkerton doctrine, a conspirator may be found guilty of a crime that he or she did not commit if the state can establish that a *828 coconspirator did commit the crime” [internal quotation marks omitted]).

2011Accordingly, for the defendant to be convicted of the crime of assault in the first degree under the Pinkerton doctrine of vicarious liability, the state was required to prove, beyond a reasonable doubt, that the crime of assault in the first degree was committed by the defendant’s coconspirator, Bodamer. 3 See State v. Martinez, 278 Conn. 598, 618 , 900 A.2d 485 (2006) (“under the Pinkerton doctrine, a conspirator may be found guilty of a crime that he or she did not commit if the state can establish that a *828 coconspirator did commit the crime” [internal quotation marks omitted]).

12011–2011
State v. Tucker green
conn · 1993
2 sentences

2006That is, one with which you all agree.” 17 The defendant argued before the trial court that this court’s decision in State v. Coltherst, 263 Conn. 478 , 820 A.2d 1024 (2003), “does not support *608 the proposition that the court can instruct a lack of unanimity on those three different forms of liability.” The trial court, however, agreed with the state’s position that its charge was proper in light of this court’s decision in State v. Correa, supra, 241 Conn. 322 , and ruled that the instruction would remain as read because “coconspirator liability is a vicarious liability principle just like

2006That is, one with which you all agree.” 17 The defendant argued before the trial court that this court’s decision in State v. Coltherst, 263 Conn. 478 , 820 A.2d 1024 (2003), “does not support *608 the proposition that the court can instruct a lack of unanimity on those three different forms of liability.” The trial court, however, agreed with the state’s position that its charge was proper in light of this court’s decision in State v. Correa, supra, 241 Conn. 322 , and ruled that the instruction would remain as read because “coconspirator liability is a vicarious liability principle just like

12006–2006
State v. Correa green
conn · 1997
1 sentence

2006That is, one with which you all agree.” 17 The defendant argued before the trial court that this court’s decision in State v. Coltherst, 263 Conn. 478 , 820 A.2d 1024 (2003), “does not support *608 the proposition that the court can instruct a lack of unanimity on those three different forms of liability.” The trial court, however, agreed with the state’s position that its charge was proper in light of this court’s decision in State v. Correa, supra, 241 Conn. 322 , and ruled that the instruction would remain as read because “coconspirator liability is a vicarious liability principle just like

12006–2006
United States v. Charles Lidge Bolts and Joe Dee Hicks green
ca5 · 1977
1 sentence

2006That is, one with which you all agree.” 17 The defendant argued before the trial court that this court’s decision in State v. Coltherst, 263 Conn. 478 , 820 A.2d 1024 (2003), “does not support *608 the proposition that the court can instruct a lack of unanimity on those three different forms of liability.” The trial court, however, agreed with the state’s position that its charge was proper in light of this court’s decision in State v. Correa, supra, 241 Conn. 322 , and ruled that the instruction would remain as read because “coconspirator liability is a vicarious liability principle just like

12006–2006
Porebski v. United States green
scotus · 1977
1 sentence

2006Hicks v. United States, 434 U.S. 930 , 98 S. Ct. 417 , 54 L.

12006–2006
Hicks v. United States green
scotus · 1977
1 sentence

2006Hicks v. United States, 434 U.S. 930 , 98 S. Ct. 417 , 54 L.

12006–2006
Maisenbacker v. Society Concordia green
conn · 1899
1 sentence

1999Defendant cites Maisenbacker v. Society Concordia , 71 Conn. 369 , 379 (1899) for the proposition that there is no vicarious liability for punitive or exemplary damages at common law.

11999–1999
Elias v. Unisys Corp. green
mass · 1991
2 sentences

1999Elias v. Unisys Corp., 410 Mass. 479, 481 , 573 N.E.2d 946 (1991); Theophelis v. Lansing General Hospital, supra, 488-89.

1999Elias v. Unisys Corp., 410 Mass. 479, 481 , 573 N.E.2d 946 (1991); Theophelis v. Lansing General Hospital, supra, 488-89.

11999–1999

Statutes the citing opinions construe

CT § Conn. Gen. Stat. § 53a-48 (6) CT § Conn. Gen. Stat. § 53a-49 (5) CT § Conn. Gen. Stat. § 53a-8 (4) CT § Conn. Gen. Stat. § 51-199 (3) CT § Conn. Gen. Stat. § 53a-217 (3) CT § Conn. Gen. Stat. § 53a-59 (3) CT § Conn. Gen. Stat. § 53a-92 (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 51 (2002–2026) NY 28 (1972–2026) FL 26 (1977–2024) MI 24 (1980–2025) IL 21 (1976–2026) CA 16 (1978–2017) PA 16 (1987–2021) TN 15 (1966–2025) IN 15 (1979–2025) NJ 14 (1993–2026) AZ 13 (1992–2025) CT 13 (1999–2024) MS 12 (2004–2023) GA 12 (2000–2023) OH 11 (2005–2025) LA 8 (2004–2025) WI 8 (1996–2025) CO 7 (1968–2021) MO 7 (1995–2024) IA 7 (1991–2026) NV 6 (1978–2021) MN 6 (1961–2024) MD 4 (2013–2026) DE 4 (2015–2020) AL 4 (2005–2025) KS 4 (1983–2022) NM 4 (2012–2023) DC 4 (1997–2020) WY 3 (2001–2025) MA 3 (1983–2023) AK 3 (1980–2002) WA 3 (2013–2025) SD 3 (2000–2012) WV 3 (2001–2024) VA 3 (2005–2018) OR 2 (2008–2009) NH 2 (2006–2009) NC 2 (1999–2002) ME 2 (2009–2010) KY 2 (2001–2006) UT 2 (2011–2023) AR 2 (2013–2021)

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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