equitable tolling doctrine (Connecticut) · Go Syfert
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equitable tolling doctrine in Connecticut

10 Connecticut opinions name it 3 courts 1996–2019 0 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
Williams v. Commission On Human Rights & Opportunitiesgreen
conn · 2001 · cited in 2 Connecticut opinions naming this issue, 2008–2018
2 sentences

2018In support of this contention, the defendants cite to Williams v. Commission on Human Rights & Opportunities , 257 Conn. 258 , 777 A.2d 645 (2001), which, they argue, stands for the proposition that "the doctrine of equitable tolling does not apply when the statute [of limitations] at issue implicates subject matter jurisdiction." Relying on Williams , the defendants contend that, because the continuing course of conduct and continuing course of treatment doctrines are equitable doctrines, and because the repose provision of § 52-555 implicates the court's subject matter jurisdiction, the plai

2018In support of this contention, the defendants cite to Williams v. Commission on Human Rights & Opportunities , 257 Conn. 258 , 777 A.2d 645 (2001), which, they argue, stands for the proposition that "the doctrine of equitable tolling does not apply when the statute [of limitations] at issue implicates subject matter jurisdiction." Relying on Williams , the defendants contend that, because the continuing course of conduct and continuing course of treatment doctrines are equitable doctrines, and because the repose provision of § 52-555 implicates the court's subject matter jurisdiction, the plai

12
D'Agostino v. Housing Authoritygreen
conn · 2006 · cited in 1 Connecticut opinions naming this issue, 2018–2018
1 sentence

2018We conclude that the defendants' reliance on Williams is misplaced because, unlike the doctrine of equitable tolling at issue in Williams , which, when applicable, allows an untimely action to proceed; see, e.g., Gager v. Sanger , 95 Conn. App. 632 , 638, 897 A.2d 704 ("[t]he doctrine of equitable tolling applies in certain situations to excuse untimeliness in filing a complaint"), **270 cert. denied, 280 Conn. 905 , 907 A.2d 90 (2006) ; the continuing course of conduct and continuing course of treatment doctrines are utilized to determine whether an action is timely even though some of the ac

11
Gager v. Sangergreen
connappct · 2006 · cited in 1 Connecticut opinions naming this issue, 2018–2018
2 sentences

2018We conclude that the defendants' reliance on Williams is misplaced because, unlike the doctrine of equitable tolling at issue in Williams , which, when applicable, allows an untimely action to proceed; see, e.g., Gager v. Sanger , 95 Conn. App. 632 , 638, 897 A.2d 704 ("[t]he doctrine of equitable tolling applies in certain situations to excuse untimeliness in filing a complaint"), **270 cert. denied, 280 Conn. 905 , 907 A.2d 90 (2006) ; the continuing course of conduct and continuing course of treatment doctrines are utilized to determine whether an action is timely even though some of the ac

2018We conclude that the defendants' reliance on Williams is misplaced because, unlike the doctrine of equitable tolling at issue in Williams , which, when applicable, allows an untimely action to proceed; see, e.g., Gager v. Sanger , 95 Conn. App. 632 , 638, 897 A.2d 704 ("[t]he doctrine of equitable tolling applies in certain situations to excuse untimeliness in filing a complaint"), **270 cert. denied, 280 Conn. 905 , 907 A.2d 90 (2006) ; the continuing course of conduct and continuing course of treatment doctrines are utilized to determine whether an action is timely even though some of the ac

11
HOUSING AUTHORITY OF THE CITY OF NEW HAVEN v. Martingreen
conn · 2006 · cited in 1 Connecticut opinions naming this issue, 2018–2018
1 sentence

2018We conclude that the defendants' reliance on Williams is misplaced because, unlike the doctrine of equitable tolling at issue in Williams , which, when applicable, allows an untimely action to proceed; see, e.g., Gager v. Sanger , 95 Conn. App. 632 , 638, 897 A.2d 704 ("[t]he doctrine of equitable tolling applies in certain situations to excuse untimeliness in filing a complaint"), **270 cert. denied, 280 Conn. 905 , 907 A.2d 90 (2006) ; the continuing course of conduct and continuing course of treatment doctrines are utilized to determine whether an action is timely even though some of the ac

11
Glastonbury Volunteer Ambulance Ass'n v. Freedom of Information Commissiongreen
conn · 1993 · cited in 1 Connecticut opinions naming this issue, 2013–2013
2 sentences

2013See Glastonbury Volunteer Ambulance Assn., Inc. v. Freedom of Information Commission, 227 Conn. 848, 854-56 , 633 A.2d 305 (1993) (“The legislature intended the forty-five day time limitation for filing of an appeal under the [Uniform Administrative Procedure Act] to remain a prerequisite to subject matter jurisdiction. ...

2013See Glastonbury Volunteer Ambulance Assn., Inc. v. Freedom of Information Commission, 227 Conn. 848, 854-56 , 633 A.2d 305 (1993) (“The legislature intended the forty-five day time limitation for filing of an appeal under the [Uniform Administrative Procedure Act] to remain a prerequisite to subject matter jurisdiction. ...

11
Cadlerock Properties Joint Venture, L.P. v. Commissioner of Environmental Protectiongreen
conn · 2000 · cited in 1 Connecticut opinions naming this issue, 2006–2006
2 sentences

2006See Cadlerock Properties Joint Venture, L.P. v. Commissioner of Environmental Protection, 253 Conn. 661, 674-75 , 757 A.2d 1 (2000), cert. denied, 531 U.S. 1148 , 121 S. Ct. 1089 , 148 L.

2006See Cadlerock Properties Joint Venture, L.P. v. Commissioner of Environmental Protection, 253 Conn. 661, 674-75 , 757 A.2d 1 (2000), cert. denied, 531 U.S. 1148 , 121 S. Ct. 1089 , 148 L.

11
Cadlerock Properties Joint Venture, L. P. v. Connecticut Commissioner of Environmental Protectiongreen
scotus · 2001 · cited in 1 Connecticut opinions naming this issue, 2006–2006
1 sentence

2006See Cadlerock Properties Joint Venture, L.P. v. Commissioner of Environmental Protection, 253 Conn. 661, 674-75 , 757 A.2d 1 (2000), cert. denied, 531 U.S. 1148 , 121 S. Ct. 1089 , 148 L.

11
Hurley v. Motor Coach Industries, Inc.green
scotus · 2001 · cited in 1 Connecticut opinions naming this issue, 2006–2006
1 sentence

2006See Cadlerock Properties Joint Venture, L.P. v. Commissioner of Environmental Protection, 253 Conn. 661, 674-75 , 757 A.2d 1 (2000), cert. denied, 531 U.S. 1148 , 121 S. Ct. 1089 , 148 L.

11
Brass v. GDQ Corp.green
scotus · 2001 · cited in 1 Connecticut opinions naming this issue, 2006–2006
1 sentence

2006See Cadlerock Properties Joint Venture, L.P. v. Commissioner of Environmental Protection, 253 Conn. 661, 674-75 , 757 A.2d 1 (2000), cert. denied, 531 U.S. 1148 , 121 S. Ct. 1089 , 148 L.

11
Brown v. Employer's Reinsurance Corp.green
conn · 1988 · cited in 1 Connecticut opinions naming this issue, 2001–2001
2 sentences

2001See Brown v. Employer’s Reinsurance Corp., 206 Conn. 668 , 674— 77, 539 A.2d 138 (1988).

2001See Brown v. Employer’s Reinsurance Corp., 206 Conn. 668 , 674— 77, 539 A.2d 138 (1988).

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 (5)

CaseCitedYears
Turner v. State green
connappct · 2017
2 sentences

2019The doctrine of equitable tolling does not apply to subject matter jurisdiction. ‘‘Our Supreme Court has made clear that a court lacks the authority to apply the doctrine of equitable tolling or otherwise exercise discretionary authority to extend a limitations period if the applicable statute of limitations constitutes a limit on the court’s subject matter jurisdiction.’’ Turner v. State, 172 Conn. App. 352, 360 , 160 A.3d 398 (2017).

2019The doctrine of equitable tolling does not apply to subject matter jurisdiction. ‘‘Our Supreme Court has made clear that a court lacks the authority to apply the doctrine of equitable tolling or otherwise exercise discretionary authority to extend a limitations period if the applicable statute of limitations constitutes a limit on the court’s subject matter jurisdiction.’’ Turner v. State, 172 Conn. App. 352, 360 , 160 A.3d 398 (2017).

12019–2019
Allstate Insurance v. Barron green
conn · 2004
2 sentences

2014Co. v. Barron, 269 Conn. 394 , 848 A.2d 1165 (2004), did not involve an equitable tolling doctrine and, therefore, is inapposite. 25 Rule 1.7 of the Rules of Professional Conduct provides: ‘‘(a) Except as provided in subsection (b), a lawyer shall not represent a client if the representation involves a concurrent conflict of interest.

2014Co. v. Barron, 269 Conn. 394 , 848 A.2d 1165 (2004), did not involve an equitable tolling doctrine and, therefore, is inapposite. 25 Rule 1.7 of the Rules of Professional Conduct provides: ‘‘(a) Except as provided in subsection (b), a lawyer shall not represent a client if the representation involves a concurrent conflict of interest.

12014–2014
State v. Davis green
conn · 1986
2 sentences

2005See Rules of Professional Conduct 1.2, commentary; 20 State v. Davis, 199 Conn. 88, 95 , 506 A.2d 86 (1986) (decisions of trial strategy and tactics rest with attorney); See also Rules of Professional Conduct 3.1 (barring attorneys from presenting frivolous claims).

2005See Rules of Professional Conduct 1.2, commentary; 20 State v. Davis, 199 Conn. 88, 95 , 506 A.2d 86 (1986) (decisions of trial strategy and tactics rest with attorney); See also Rules of Professional Conduct 3.1 (barring attorneys from presenting frivolous claims).

12005–2005
Baldwin County Welcome Center v. Brown green
scotus · 1984
2 sentences

1997Also, see Baldwin County Welcome Center v. Brown , 466 U.S. 147 , 152 (1984), where in denying an equitable tolling claim the court noted: "[S]trict adherence to the procedural requirements specified by the legislature is the best guarantee of evenhanded administration of the law." Baldwin County Welcome Center v. Brown , 466 U.S. 147 , 152 (1984).

1997Also, see Baldwin County Welcome Center v. Brown , 466 U.S. 147 , 152 (1984), where in denying an equitable tolling claim the court noted: "[S]trict adherence to the procedural requirements specified by the legislature is the best guarantee of evenhanded administration of the law." Baldwin County Welcome Center v. Brown , 466 U.S. 147 , 152 (1984).

11997–1997
Gallop v. Commercial Painting Co. green
connsuperct · 1992
1 sentence

1996Since Bailey, the doctrine has been held to "embrace both what is sometimes called the discovery rule, which holds that the statute begins to run only after discovery of the facts constituting the violation; and the related rule that the statute does not begin to run when a plaintiff knows that he has been injured but he cannot obtain information necessary to decide whether the injury is due to wrongdoing and, if so, wrongdoing by the defendant." CT Page 4587 Gallop v. Commercial Printing Co., 42 Conn. Sup. 187 , 192 (1992) (discussing, but not applying, the doctrine of equitable tolling).

11996–1996

Where else courts name it

CA 139 (1978–2026) PA 119 (2000–2026) WA 33 (1994–2026) TX 32 (1990–2026) FL 23 (1986–2026) IL 22 (1989–2026) AL 20 (2007–2026) IA 19 (1998–2025) OH 17 (1998–2026) SC 16 (2008–2025) NJ 16 (1997–2026) MT 15 (1988–2025) DE 15 (2013–2026) ND 13 (1997–2023) DC 13 (1983–2025) CO 12 (1995–2025) MI 10 (2005–2024) CT 10 (1996–2019) NM 10 (1986–2015) AZ 8 (1985–2020) TN 8 (1996–2022) KY 8 (2005–2026) UT 8 (2001–2021) SD 6 (2000–2024) NV 6 (1983–2021) AR 5 (2003–2024) VI 5 (2009–2025) MS 5 (1991–2015) MA 4 (1999–2024) NY 4 (2007–2020) MN 4 (1981–2015) AK 4 (1989–2013) MD 4 (1993–2013) HI 4 (1998–2024) RI 3 (2002–2017) NE 3 (1996–2024) VA 2 (2004–2012) GA 2 (2009–2020) ME 2 (2017–2025) WV 2 (2021–2022) OK 2 (1986–1999) VT 2 (1999–2024) NC 2 (1994–2014) ID 2 (2007–2025)

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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