Already have an account? Sign in instead.
You stay signed in for 30 days on this browser.
Continue with Google Continue with MicrosoftNo account yet? Create a free one.
We sent a six-digit code.
It expires in ten minutes, works once, and only in this browser. Five wrong tries void it. Send another code.
Your account is live and the Cloudflare checks are off for this browser.
12 Connecticut opinions name it 3 courts 1997–2025 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.
| Case | Followed | Cited |
|---|---|---|
State v. Wrightgreen2 sentences2025See, e.g., State v. Wright, 273 Conn. 418, 424, 426 , 870 A.2d 1039 (2005). ‘‘[A]n order issued by a court of competent jurisdiction must be obeyed by the parties until it is reversed by orderly and proper proceedings. . . . [A] party has a duty to obey a court order however errone- ous the action of the court may be . . . . [T]here is no privilege to disobey a court’s order because the alleged contemnor believes that it is invalid. . . . [T]his doc- trine, which is commonly known as the collateral bar rule, is justified on the ground that it advances important societal interests in an orderly 2025See, e.g., State v. Wright, 273 Conn. 418, 424, 426 , 870 A.2d 1039 (2005). ‘‘[A]n order issued by a court of competent jurisdiction must be obeyed by the parties until it is reversed by orderly and proper proceedings. . . . [A] party has a duty to obey a court order however errone- ous the action of the court may be . . . . [T]here is no privilege to disobey a court’s order because the alleged contemnor believes that it is invalid. . . . [T]his doc- trine, which is commonly known as the collateral bar rule, is justified on the ground that it advances important societal interests in an orderly | 1 | 3 |
Cologne v. Westfarms Associatesgreen2 sentences2009The court also finds *501 that the defendant has not met his burden to demonstrate that the collateral attack on the order in this proceeding is appropriate pursuant to [State v. Wright, 273 Conn. 418, 426 , 870 A.2d 1039 (2005)].” The collateral bar' rule, initially applied in the context of a contempt proceeding, holds that “a contempt proceeding does not open to reconsideration the legal or factual basis of the order alleged to have been disobeyed”; (internal quotation marks omitted) Cologne v. Westfarms Associates, 197 Conn. 141, 148 , 496 A.2d 476 (1985); and that “there is no privilege t 2009The court also finds *501 that the defendant has not met his burden to demonstrate that the collateral attack on the order in this proceeding is appropriate pursuant to [State v. Wright, 273 Conn. 418, 426 , 870 A.2d 1039 (2005)].” The collateral bar' rule, initially applied in the context of a contempt proceeding, holds that “a contempt proceeding does not open to reconsideration the legal or factual basis of the order alleged to have been disobeyed”; (internal quotation marks omitted) Cologne v. Westfarms Associates, 197 Conn. 141, 148 , 496 A.2d 476 (1985); and that “there is no privilege t | 1 | 3 |
Mendillo v. Tinley, Renehan & Dost, LLPgreen2 sentences2023Notably, in Valvo, we character- ized the plaintiff’s collateral challenge as moot and ‘‘nonjusticiable because no practical relief [was] avail- able . . . .’’ Id., 548 ; see also Mendillo v. Tinley, Renehan & Dost, LLP, 329 Conn. 515, 527 , 187 A.3d 1154 (2018) (‘‘we agree with the defendants that the . . . case is nonjusticiable because no practical relief is available to the plaintiff insofar as the allegations in the declaratory judgment complaint demonstrate that it is nothing more than a collateral attack on the protec- tive order imposed by the trial court [in a different case]’’). 2023Notably, in Valvo, we character- ized the plaintiff’s collateral challenge as moot and ‘‘nonjusticiable because no practical relief [was] avail- able . . . .’’ Id., 548 ; see also Mendillo v. Tinley, Renehan & Dost, LLP, 329 Conn. 515, 527 , 187 A.3d 1154 (2018) (‘‘we agree with the defendants that the . . . case is nonjusticiable because no practical relief is available to the plaintiff insofar as the allegations in the declaratory judgment complaint demonstrate that it is nothing more than a collateral attack on the protec- tive order imposed by the trial court [in a different case]’’). | 1 | 1 |
Hirtle v. Hirtlegreen2 sentences2016See Hirtle v. Hirtle, supra, 217 Conn. at 403 , 586 A.2d 578 ("On this meager record, the defendant has failed to overcome the presumption that [the trial court] was reading from a written document when he described the terms of the modified support order to which the parties had agreed. 2016See Hirtle v. Hirtle, supra, 217 Conn. at 403 , 586 A.2d 578 ("On this meager record, the defendant has failed to overcome the presumption that [the trial court] was reading from a written document when he described the terms of the modified support order to which the parties had agreed. | 1 | 1 |
Morris v. Irwingreen2 sentences2016Although it is axiomatic that parties cannot confer jurisdiction on a court by consent; see, e.g., Keller v. Beckenstein, supra, 305 Conn. at 531 , 46 A.3d 102 ; Morris v. Irwin, supra, 4 Conn.App. at 435 , 494 A.2d 626 ; the defendant's assent to the modification undercuts her contention that the modification was a miscarriage of justice deserving of disruption on collateral review. 22 This is particularly so, given that Judge Resha's ratification of the parties' agreement to modify the original judgment of dissolution was not so far afield from the Superior Court's plenary jurisdiction over 2016Although it is axiomatic that parties cannot confer jurisdiction on a court by consent; see, e.g., Keller v. Beckenstein, supra, 305 Conn. at 531 , 46 A.3d 102 ; Morris v. Irwin, supra, 4 Conn.App. at 435 , 494 A.2d 626 ; the defendant's assent to the modification undercuts her contention that the modification was a miscarriage of justice deserving of disruption on collateral review. 22 This is particularly so, given that Judge Resha's ratification of the parties' agreement to modify the original judgment of dissolution was not so far afield from the Superior Court's plenary jurisdiction over | 1 | 1 |
Brennan v. Manlapazgreen1 sentence2016See id., at 71 , 560 A.2d 988 ("In this case, the original trial court's award of the principal of the trusts was only one part of a financial award that included alimony, child support, medical insurance, beneficiary interests in life insurance policies and attorney's fees. | 1 | 1 |
Joyce O. Hodge v. Stedmann Hodgegreen2 sentences2016See Hodge v. Hodge, 621 F.2d 590 , 592-93 (3d Cir.1980) (relying on presumption of finality under § 15 of sixth tentative draft of Restatement [Second] of Judgments to reject collateral attack on territorial court of general jurisdiction's statutorily unauthorized award of real estate pursuant to dissolution settlement because parties agreed to judgment and failed to contest jurisdiction at that time); Vogel v. Vogel, supra, 178 Conn. at 363 , 422 A.2d 271 (rejecting collateral challenge because, inter alia, husband "not only was fully aware of the consequences of the decrees and had the oppor 2016See Hodge v. Hodge, 621 F.2d 590 , 592–93 (3d Cir. 1980) (relying on presumption of finality under § 15 of sixth tentative draft of Restatement [Second] of Judgments to reject collateral attack on territorial court of general jurisdiction’s statutorily unauthorized award of real estate pursuant to dissolu- tion settlement because parties agreed to judgment and failed to contest jurisdiction at that time); Vogel v. Vogel, supra, 178 Conn. 363 (rejecting collateral challenge because, inter alia, husband ‘‘not only was fully aware of the consequences of the decrees and had the opportu- nity to fu | 1 | 1 |
United States v. Yassem Fares, Also Known as Yasser Faresgreen1 sentence2007Mere assertions and generalized proffers on information and belief are insufficient.” (Citations omitted; internal quotation marks omitted.) United States v. Fares, 978 F.2d 52, 59 (2d Cir. 1992). “[T]o engage in a collateral inquiry respecting prosecutorial motive, there must be more than mere suspicion or surmise. | 1 | 1 |
Walker v. City of Birminghamgreen2 sentences2005See, e.g., Walker v. Birmingham, 388 U.S. 307, 312, 315 , 87 S. Ct. 1824 , 18 L. 2005See, e.g., Walker v. Birmingham, 388 U.S. 307, 312, 315 , 87 S. Ct. 1824 , 18 L. | 1 | 1 |
Vecchio v. Sewer Authoritygreen2 sentences2002See Vecchio v. Sewer Authority, 176 Conn. 497, 500 , 408 A.2d 254 (1979); Vaill v. Sewer Commission, 168 Conn. 514, 518-19 , 362 A.2d 885 (1975). 2002See Vecchio v. Sewer Authority, 176 Conn. 497, 500 , 408 A.2d 254 (1979); Vaill v. Sewer Commission, 168 Conn. 514, 518-19 , 362 A.2d 885 (1975). | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Connecticut. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
New York State Rifle & Pistol Assn., Inc. v. Bruen
green
2 sentences2025He argues that, because ‘‘the legal authority necessary to challenge the constitu- tionality of a protective [order] did not exist at the time of his arrest, [his] criminal case is the appropriate forum to resolve his challenge.’’ The second amendment authorities that postdate the defendant’s protective orders are the United States Supreme Court’s recent decisions in New York State Rifle & Pistol Assn., Inc. v. Bruen, 597 U.S. 1 , 142 S. Ct. 2111 , 213 L. 2025He argues that, because ‘‘the legal authority necessary to challenge the constitu- tionality of a protective [order] did not exist at the time of his arrest, [his] criminal case is the appropriate forum to resolve his challenge.’’ The second amendment authorities that postdate the defendant’s protective orders are the United States Supreme Court’s recent decisions in New York State Rifle & Pistol Assn., Inc. v. Bruen, 597 U.S. 1 , 142 S. Ct. 2111 , 213 L. | 1 | 2025–2025 |
Grimm v. Grimm
green
2 sentences2025In this opinion the other justices concurred. 7 To the extent that the defendant claims that the criminal statutes them- selves are unconstitutional, this claim is inadequately briefed. ‘‘Claims that are inadequately briefed generally are considered abandoned.’’ Grimm v. Grimm, 276 Conn. 377, 393 , 886 A.2d 391 (2005), cert. denied, 547 U.S. 1148 , 126 S. Ct. 2296 , 164 L. 2025In this opinion the other justices concurred. 7 To the extent that the defendant claims that the criminal statutes them- selves are unconstitutional, this claim is inadequately briefed. ‘‘Claims that are inadequately briefed generally are considered abandoned.’’ Grimm v. Grimm, 276 Conn. 377, 393 , 886 A.2d 391 (2005), cert. denied, 547 U.S. 1148 , 126 S. Ct. 2296 , 164 L. | 1 | 2025–2025 |
Baker v. Marion County Office of Family & Children
green
1 sentence2017The resolution of a civil juvenile proceeding focuses on the best interests of the child, not on guilt or innocence as in a criminal proceeding." Baker v. Office of Family & Children , 810 N.E.2d 1035 , 1039 (Ind. 2004). | 1 | 2017–2017 |
In re Shamika F.
green
2 sentences2016Insofar as the jurisdictional deficiency must be apparent from the face of the record for purposes of a collateral challenge, and we indulge every presumption in favor of subject matter jurisdiction; see, e.g., Investment Associates v. Summit Associates, Inc., supra, 309 Conn. at 858 , 74 A.3d 1192 ; In re Shamika F., supra, 256 Conn. at 406 -407 , 773 A.2d 347 ; even assuming that § 46b-66 (a) is jurisdictional in nature, we read Judge Resha's canvass of the defendant to comport with that provision. 2016Insofar as the jurisdictional deficiency must be apparent from the face of the record for purposes of a collateral challenge, and we indulge every presumption in favor of subject matter jurisdiction; see, e.g., Investment Associates v. Summit Associates, Inc., supra, 309 Conn. at 858 , 74 A.3d 1192 ; In re Shamika F., supra, 256 Conn. at 406 -407 , 773 A.2d 347 ; even assuming that § 46b-66 (a) is jurisdictional in nature, we read Judge Resha's canvass of the defendant to comport with that provision. | 1 | 2016–2016 |
Daly v. Daly
green
2 sentences2016In Daly v. Daly, supra, 19 Conn.App. at 70 -72 , 561 A.2d 951 the Appellate Court relied on the mosaic theory to reject a collateral challenge to the nineteen year old original judgment of dissolution, only part of which-ordering distribution of the principal of a trust-was claimed to be jurisdictionally defective as beyond the court's authority. 2016In Daly v. Daly, supra, 19 Conn.App. at 70 -72 , 561 A.2d 951 the Appellate Court relied on the mosaic theory to reject a collateral challenge to the nineteen year old original judgment of dissolution, only part of which-ordering distribution of the principal of a trust-was claimed to be jurisdictionally defective as beyond the court's authority. | 1 | 2016–2016 |
State v. Diaz
green
1 sentence2016See Hodge v. Hodge, 621 F.2d 590 , 592–93 (3d Cir. 1980) (relying on presumption of finality under § 15 of sixth tentative draft of Restatement [Second] of Judgments to reject collateral attack on territorial court of general jurisdiction’s statutorily unauthorized award of real estate pursuant to dissolu- tion settlement because parties agreed to judgment and failed to contest jurisdiction at that time); Vogel v. Vogel, supra, 178 Conn. 363 (rejecting collateral challenge because, inter alia, husband ‘‘not only was fully aware of the consequences of the decrees and had the opportu- nity to fu | 1 | 2016–2016 |
URBAN REDEV. COM'N OF STAMFORD v. Katsetos
green
2 sentences2016See Hodge v. Hodge, 621 F.2d 590 , 592-93 (3d Cir.1980) (relying on presumption of finality under § 15 of sixth tentative draft of Restatement [Second] of Judgments to reject collateral attack on territorial court of general jurisdiction's statutorily unauthorized award of real estate pursuant to dissolution settlement because parties agreed to judgment and failed to contest jurisdiction at that time); Vogel v. Vogel, supra, 178 Conn. at 363 , 422 A.2d 271 (rejecting collateral challenge because, inter alia, husband "not only was fully aware of the consequences of the decrees and had the oppor 2016See Hodge v. Hodge, 621 F.2d 590 , 592-93 (3d Cir.1980) (relying on presumption of finality under § 15 of sixth tentative draft of Restatement [Second] of Judgments to reject collateral attack on territorial court of general jurisdiction's statutorily unauthorized award of real estate pursuant to dissolution settlement because parties agreed to judgment and failed to contest jurisdiction at that time); Vogel v. Vogel, supra, 178 Conn. at 363 , 422 A.2d 271 (rejecting collateral challenge because, inter alia, husband "not only was fully aware of the consequences of the decrees and had the oppor | 1 | 2016–2016 |
Monroe v. Monroe
green
2 sentences2016The modified judgment of postmajority support has therefore not been shown to be jurisdictionally defective."); Monroe v. Monroe, supra, 177 Conn. at 184-85 , 413 A.2d 819 (The court rejected a collateral challenge to the jurisdiction of a judge trial referee because "[t]he absence from the case file of a signed order is by no means conclusive evidence on the face of the record that the Superior Court judge never heard or acted upon the motion to refer the case. 2016The modified judgment of postmajority support has therefore not been shown to be jurisdictionally defective."); Monroe v. Monroe, supra, 177 Conn. at 184-85 , 413 A.2d 819 (The court rejected a collateral challenge to the jurisdiction of a judge trial referee because "[t]he absence from the case file of a signed order is by no means conclusive evidence on the face of the record that the Superior Court judge never heard or acted upon the motion to refer the case. | 1 | 2016–2016 |
Vogel v. Vogel
green
2 sentences2016See Hodge v. Hodge, 621 F.2d 590 , 592-93 (3d Cir.1980) (relying on presumption of finality under § 15 of sixth tentative draft of Restatement [Second] of Judgments to reject collateral attack on territorial court of general jurisdiction's statutorily unauthorized award of real estate pursuant to dissolution settlement because parties agreed to judgment and failed to contest jurisdiction at that time); Vogel v. Vogel, supra, 178 Conn. at 363 , 422 A.2d 271 (rejecting collateral challenge because, inter alia, husband "not only was fully aware of the consequences of the decrees and had the oppor 2016See Hodge v. Hodge, 621 F.2d 590 , 592-93 (3d Cir.1980) (relying on presumption of finality under § 15 of sixth tentative draft of Restatement [Second] of Judgments to reject collateral attack on territorial court of general jurisdiction's statutorily unauthorized award of real estate pursuant to dissolution settlement because parties agreed to judgment and failed to contest jurisdiction at that time); Vogel v. Vogel, supra, 178 Conn. at 363 , 422 A.2d 271 (rejecting collateral challenge because, inter alia, husband "not only was fully aware of the consequences of the decrees and had the oppor | 1 | 2016–2016 |
Birnie v. Electric Boat Corp.
green
1 sentence2012Id., at 395, 402 , 953 A.2d 28 . | 1 | 2012–2012 |
State v. Winter
green
2 sentences2011The collateral bar rule has been extended to apply to situations in which . . . the defendant seeks to attack the validity of a court order in a criminal proceeding, and the rule is justified on the ground that it advances important societal interests in an orderly system of government, respect for the judicial process and the rule of law, and the preservation of civil order. [A]n order issued by a court of competent jurisdiction must be obeyed by the parties until it is reversed by orderly and proper proceedings. ... [A] party has the duty to obey a court order however erroneous [the party ma 2011The collateral bar rule has been extended to apply to situations in which . . . the defendant seeks to attack the validity of a court order in a criminal proceeding, and the rule is justified on the ground that it advances important societal interests in an orderly system of government, respect for the judicial process and the rule of law, and the preservation of civil order. [A]n order issued by a court of competent jurisdiction must be obeyed by the parties until it is reversed by orderly and proper proceedings. ... [A] party has the duty to obey a court order however erroneous [the party ma | 1 | 2011–2011 |
Chase Home Finance, LLC v. Fequiere
green
2 sentences2011The collateral bar rule has been extended to apply to situations in which . . . the defendant seeks to attack the validity of a court order in a criminal proceeding, and the rule is justified on the ground that it advances important societal interests in an orderly system of government, respect for the judicial process and the rule of law, and the preservation of civil order. [A]n order issued by a court of competent jurisdiction must be obeyed by the parties until it is reversed by orderly and proper proceedings. ... [A] party has the duty to obey a court order however erroneous [the party ma 2011The collateral bar rule has been extended to apply to situations in which . . . the defendant seeks to attack the validity of a court order in a criminal proceeding, and the rule is justified on the ground that it advances important societal interests in an orderly system of government, respect for the judicial process and the rule of law, and the preservation of civil order. [A]n order issued by a court of competent jurisdiction must be obeyed by the parties until it is reversed by orderly and proper proceedings. ... [A] party has the duty to obey a court order however erroneous [the party ma | 1 | 2011–2011 |
State v. Winter
green
2 sentences2011The collateral bar rule has been extended to apply to situations in which . . . the defendant seeks to attack the validity of a court order in a criminal proceeding, and the rule is justified on the ground that it advances important societal interests in an orderly system of government, respect for the judicial process and the rule of law, and the preservation of civil order. [A]n order issued by a court of competent jurisdiction must be obeyed by the parties until it is reversed by orderly and proper proceedings. ... [A] party has the duty to obey a court order however erroneous [the party ma 2011The collateral bar rule has been extended to apply to situations in which . . . the defendant seeks to attack the validity of a court order in a criminal proceeding, and the rule is justified on the ground that it advances important societal interests in an orderly system of government, respect for the judicial process and the rule of law, and the preservation of civil order. [A]n order issued by a court of competent jurisdiction must be obeyed by the parties until it is reversed by orderly and proper proceedings. ... [A] party has the duty to obey a court order however erroneous [the party ma | 1 | 2011–2011 |
Zoll v. Zoll
green
2 sentences2009The collateral bar rule has been extended to apply to situations in which, as in this case, the defendant seeks to attack the validity of a court order in a criminal proceeding, and the rule “is justified on the ground that it advances important societal interests in an orderly system of government, respect for the judicial process and the rule of law, and the preservation of civil order.” State v. Wright, supra, 273 Conn. 426 . “[A]n order issued by a court of competent jurisdiction must be obeyed by the parties until it is reversed by orderly and proper proceedings. ... [A] party has the dut 2009The collateral bar rule has been extended to apply to situations in which, as in this case, the defendant seeks to attack the validity of a court order in a criminal proceeding, and the rule “is justified on the ground that it advances important societal interests in an orderly system of government, respect for the judicial process and the rule of law, and the preservation of civil order.” State v. Wright, supra, 273 Conn. 426 . “[A]n order issued by a court of competent jurisdiction must be obeyed by the parties until it is reversed by orderly and proper proceedings. ... [A] party has the dut | 1 | 2009–2009 |
In Re Roger Novak
green
1 sentence2005Third, the order must not require an irretrievable surrender of constitutional guarantees.” (Citations omitted; internal quotation marks omitted.) In re Novak, supra, 932 F.2d 1401 . | 1 | 2005–2005 |
Cohn v. City & Town of Hartford
green
2 sentences2002In Cohn v. Hartford, 130 Conn. 699, 703 , 37 A.2d 237 (1944), we recognized, with respect to property tax assessments, that, under the common law, “where there was misfeasance or nonfeasance by the taxing authorities or the assessment was arbitrary or so excessive or discriminatory as in itself to show a disregard of duty,” relief could be given in equity in the absence of statutory authority. 2002In Cohn v. Hartford, 130 Conn. 699, 703 , 37 A.2d 237 (1944), we recognized, with respect to property tax assessments, that, under the common law, “where there was misfeasance or nonfeasance by the taxing authorities or the assessment was arbitrary or so excessive or discriminatory as in itself to show a disregard of duty,” relief could be given in equity in the absence of statutory authority. | 1 | 2002–2002 |
Vaill v. Sewer Commission
green
2 sentences2002See Vecchio v. Sewer Authority, 176 Conn. 497, 500 , 408 A.2d 254 (1979); Vaill v. Sewer Commission, 168 Conn. 514, 518-19 , 362 A.2d 885 (1975). 2002See Vecchio v. Sewer Authority, 176 Conn. 497, 500 , 408 A.2d 254 (1979); Vaill v. Sewer Commission, 168 Conn. 514, 518-19 , 362 A.2d 885 (1975). | 1 | 2002–2002 |
United States v. Mendoza-Lopez
green
2 sentences1997United CT Page 8853 States v. Mendoza-Lopez, 481 U.S. 828 , 95 L.Ed.2d 772 , 107 S.Ct. 2148 (1987). 1997United CT Page 8853 States v. Mendoza-Lopez, 481 U.S. 828 , 95 L.Ed.2d 772 , 107 S.Ct. 2148 (1987). | 1 | 1997–1997 |
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.
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.