instrumentality rule (Connecticut) · Go Syfert
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instrumentality rule in Connecticut

65 Connecticut opinions name it 3 courts 1987–2026 4 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 (16)

CaseFollowedCited
Angelo Tomasso, Inc. v. Armor Construction & Paving, Inc.green
conn · 1982 · cited in 26 Connecticut opinions naming this issue, 1989–2023
2 sentences

2023In Connecticut, courts recognize two theories under which the corporate veil may be pierced, namely, the instrumentality rule and the identity rule.8 See, e.g., Angelo Tomasso, Inc. v. Armor Construction & Paving, Inc., 187 Conn. 544 , 552–54, 447 A.2d 406 (1982).

2023In Connecticut, courts recognize two theories under which the corporate veil may be pierced, namely, the instrumentality rule and the identity rule.8 See, e.g., Angelo Tomasso, Inc. v. Armor Construction & Paving, Inc., 187 Conn. 544 , 552–54, 447 A.2d 406 (1982).

826
Campisano v. Nardigreen
conn · 1989 · cited in 11 Connecticut opinions naming this issue, 1990–2010
2 sentences

2010See, e.g., Campisano v. Nardi, supra, 212 Conn. at 293 , 562 A.2d 1 (rejecting "proposition that the instrumentality rule is triggered whenever individual control of a corporation is coupled *342 with a breach of contract by the corporation").

2010See, e.g., Campisano v. Nardi, supra, 212 Conn. at 293 , 562 A.2d 1 (rejecting "proposition that the instrumentality rule is triggered whenever individual control of a corporation is coupled *342 with a breach of contract by the corporation").

511
Zaist v. Olsongreen
conn · 1967 · cited in 18 Connecticut opinions naming this issue, 1989–2019
2 sentences

2019The identity rule, which this court has observed "complement[s] the instrumentality rule," has one prong, which requires the plaintiff to show "that there was such a unity of interest and ownership that the independence of the corporations had in effect ceased or had never begun, [in which case] an adherence to the fiction of separate identity would serve only to defeat justice and equity by permitting the economic entity to escape liability arising out of an operation conducted by one corporation for the benefit of the whole enterprise." (Internal quotation marks omitted.) Zaist v. Olsen , su

2019The identity rule, which this court has observed "complement[s] the instrumentality rule," has one prong, which requires the plaintiff to show "that there was such a unity of interest and ownership that the independence of the corporations had in effect ceased or had never begun, [in which case] an adherence to the fiction of separate identity would serve only to defeat justice and equity by permitting the economic entity to escape liability arising out of an operation conducted by one corporation for the benefit of the whole enterprise." (Internal quotation marks omitted.) Zaist v. Olsen , su

318
Toshiba America Medical Systems, Inc. v. Mobile Medical Systems, Inc.green
connappct · 1999 · cited in 4 Connecticut opinions naming this issue, 1999–2002
2 sentences

2002According to Mary Ann Howell, sometime prior to the formation of Design, the corporation against which the plaintiff also had obtained its judgment, Interiors, “|j]ust dissolved.” We reject the defendants’ assertion that the plaintiff was required to prove the elements of fraud for the second element of the rule to be satisfied. '‘The instrumentality rule merely requires the trial court to find that the defendants committed an unjust act in contravention of the plaintiffs legal rights.” Toshiba America, Medical Systems, Inc. v. Mobile Medical Systems, Inc., 53 Conn. App. 484, 491 , 730 A.2d 12

2002According to Mary Ann Howell, sometime prior to the formation of Design, the corporation against which the plaintiff also had obtained its judgment, Interiors, “|j]ust dissolved.” We reject the defendants’ assertion that the plaintiff was required to prove the elements of fraud for the second element of the rule to be satisfied. '‘The instrumentality rule merely requires the trial court to find that the defendants committed an unjust act in contravention of the plaintiffs legal rights.” Toshiba America, Medical Systems, Inc. v. Mobile Medical Systems, Inc., 53 Conn. App. 484, 491 , 730 A.2d 12

24
Hersey v. Lonrho, Inc.green
connappct · 2002 · cited in 3 Connecticut opinions naming this issue, 2003–2022
2 sentences

2008Specifically invoking the instrumentality test for piercing the corporate veil; see Hersey v. Lonrho, 73 Conn. App. 78, 87 , 807 A.2d 1009 (2002); the court made the following findings.

2008Specifically invoking the instrumentality test for piercing the corporate veil; see Hersey v. Lonrho, 73 Conn. App. 78, 87 , 807 A.2d 1009 (2002); the court made the following findings.

23
Saphir v. Neustadtgreen
conn · 1979 · cited in 8 Connecticut opinions naming this issue, 1987–2023
2 sentences

1995Zaist states that "The instrumentality rule requires, in any case but an express agency, proof of three elements: (1) Control, not mere majority or complete stock control, but complete domination, not only of finances but of policy and business practice in respect to the transaction attacked so that the corporate entity as to this transaction had at the time no separate mind, will or existence of its own; (2) that such control must have been used by the defendant to commit fraud or wrong, to perpetrate the violation of a statutory or other CT Page 12025 positive legal duty, or a dishonest or u

1994Zaist v. Olson, supra, 578 .' Saphir v. Neustadt, 177 Conn. 191 , 209-10 , 413 A.2d 843 (1979). `The instrumentality rule requires, in any case but an express agency, proof of three elements: (1) Control, not mere majority or complete stock control, but complete domination, not only of finances but of policy and business practice in respect to the transaction attacked so that the corporate entity as to this transaction had at the time no separate mind, will or existence of its own; (2) that such control must have been used by the defendant to commit fraud or wrong, to perpetrate the violation

18
Morris v. Cee Dee, LLCgreen
connappct · 2005 · cited in 3 Connecticut opinions naming this issue, 2009–2026
2 sentences

2019Morris v. Cee Dee, LLC, 90 Conn. App. 403, 414 , 877 A.2d 899 , cert. granted, 275 Conn. 929 , 883 A.2d 1245 (2005) (appeal withdrawn March 13, 2006). 8 The remaining prongs of the instrumentality rule, which are not impli- cated in this claim, are as follows: ‘‘(2) that such control must have been used by the defendant to commit fraud or wrong, to perpetrate the violation of a statutory or other positive legal duty, or a dishonest or unjust act in contravention of [the] plaintiff’s legal rights; and (3) that the aforesaid control and breach of duty must proximately cause the injury or unjust

2019Morris v. Cee Dee, LLC, 90 Conn. App. 403, 414 , 877 A.2d 899 , cert. granted, 275 Conn. 929 , 883 A.2d 1245 (2005) (appeal withdrawn March 13, 2006). 8 The remaining prongs of the instrumentality rule, which are not impli- cated in this claim, are as follows: ‘‘(2) that such control must have been used by the defendant to commit fraud or wrong, to perpetrate the violation of a statutory or other positive legal duty, or a dishonest or unjust act in contravention of [the] plaintiff’s legal rights; and (3) that the aforesaid control and breach of duty must proximately cause the injury or unjust

13
Morris v. Cee Dee, LLCgreen
conn · 2005 · cited in 3 Connecticut opinions naming this issue, 2009–2026
2 sentences

2026See, e.g., Morris v. Cee Dee, LLC, 90 Conn. App. 403 , 414–15, 877 A.2d 899 (defining two rules to set aside protec- tion of corporate form for limited liability companies), cert. granted in part, 275 Conn. 929 , 883 A.2d 1245 (2005) (appeal withdrawn March 13, 2006).

2019Morris v. Cee Dee, LLC, 90 Conn. App. 403, 414 , 877 A.2d 899 , cert. granted, 275 Conn. 929 , 883 A.2d 1245 (2005) (appeal withdrawn March 13, 2006). 8 The remaining prongs of the instrumentality rule, which are not impli- cated in this claim, are as follows: ‘‘(2) that such control must have been used by the defendant to commit fraud or wrong, to perpetrate the violation of a statutory or other positive legal duty, or a dishonest or unjust act in contravention of [the] plaintiff’s legal rights; and (3) that the aforesaid control and breach of duty must proximately cause the injury or unjust

13
Reeder v. Administrator, Unemployment Compensation Actgreen
conn · 2005 · cited in 3 Connecticut opinions naming this issue, 2009–2026
2 sentences

2026See, e.g., Morris v. Cee Dee, LLC, 90 Conn. App. 403 , 414–15, 877 A.2d 899 (defining two rules to set aside protec- tion of corporate form for limited liability companies), cert. granted in part, 275 Conn. 929 , 883 A.2d 1245 (2005) (appeal withdrawn March 13, 2006).

2019Morris v. Cee Dee, LLC, 90 Conn. App. 403, 414 , 877 A.2d 899 , cert. granted, 275 Conn. 929 , 883 A.2d 1245 (2005) (appeal withdrawn March 13, 2006). 8 The remaining prongs of the instrumentality rule, which are not impli- cated in this claim, are as follows: ‘‘(2) that such control must have been used by the defendant to commit fraud or wrong, to perpetrate the violation of a statutory or other positive legal duty, or a dishonest or unjust act in contravention of [the] plaintiff’s legal rights; and (3) that the aforesaid control and breach of duty must proximately cause the injury or unjust

13
Twachtman v. Hastingsgreen
conn · 1999 · cited in 3 Connecticut opinions naming this issue, 2001–2002
2 sentences

2002According to Mary Ann Howell, sometime prior to the formation of Design, the corporation against which the plaintiff also had obtained its judgment, Interiors, “|j]ust dissolved.” We reject the defendants’ assertion that the plaintiff was required to prove the elements of fraud for the second element of the rule to be satisfied. '‘The instrumentality rule merely requires the trial court to find that the defendants committed an unjust act in contravention of the plaintiffs legal rights.” Toshiba America, Medical Systems, Inc. v. Mobile Medical Systems, Inc., 53 Conn. App. 484, 491 , 730 A.2d 12

2001See Toshiba America Medical Systems v. Mobile Medical Systems , 53 Conn. App. 484 , 489 , 730 A.2d 1219 ; cert. denied, 249 Conn. 930 , 733 A.2d 851 (1999).

13
State v. Kenneygreen
conn · 1999 · cited in 3 Connecticut opinions naming this issue, 2001–2002
2 sentences

2002According to Mary Ann Howell, sometime prior to the formation of Design, the corporation against which the plaintiff also had obtained its judgment, Interiors, “|j]ust dissolved.” We reject the defendants’ assertion that the plaintiff was required to prove the elements of fraud for the second element of the rule to be satisfied. '‘The instrumentality rule merely requires the trial court to find that the defendants committed an unjust act in contravention of the plaintiffs legal rights.” Toshiba America, Medical Systems, Inc. v. Mobile Medical Systems, Inc., 53 Conn. App. 484, 491 , 730 A.2d 12

2001See Toshiba America Medical Systems v. Mobile Medical Systems , 53 Conn. App. 484 , 489 , 730 A.2d 1219 ; cert. denied, 249 Conn. 930 , 733 A.2d 851 (1999).

13
Cohen v. Meyersgreen
connappct · 2017 · cited in 1 Connecticut opinions naming this issue, 2021–2021
2 sentences

2021See Cohen v. Meyers, 175 Conn. App. 519, 541 , 167 A.3d 1157 , cert. denied, 327 Conn. 973 , 174 A.3d 194 (2017).

2021See Cohen v. Meyers, 175 Conn. App. 519, 541 , 167 A.3d 1157 , cert. denied, 327 Conn. 973 , 174 A.3d 194 (2017).

11
Cohen v. Meyersgreen
conn · 2017 · cited in 1 Connecticut opinions naming this issue, 2021–2021
1 sentence

2021See Cohen v. Meyers, 175 Conn. App. 519, 541 , 167 A.3d 1157 , cert. denied, 327 Conn. 973 , 174 A.3d 194 (2017).

11
Arroyo v. Univ. of Conn. Health Ctr.green
conn · 2017 · cited in 1 Connecticut opinions naming this issue, 2021–2021
1 sentence

2021See Cohen v. Meyers, 175 Conn. App. 519, 541 , 167 A.3d 1157 , cert. denied, 327 Conn. 973 , 174 A.3d 194 (2017).

11
Litchfield Asset Management Corp. v. Howellgreen
conn · 2002 · cited in 1 Connecticut opinions naming this issue, 2008–2008
1 sentence

2008The instrumentality test for piercing the corporate veil, which the court applied in the present case, “requires, in any case but an express agency, proof of three elements: (1) Control, not mere majority or complete stock control, but complete domination, not only of finances but of policy and business practice in respect to the transaction attacked so that the corporate entity as to this transaction had at the time no separate mind, will or existence of its own; (2) that such control must have been used by the defendant to commit fraud or wrong, to perpetrate the violation of a statutory or

11
Alarm Applications Co. v. Simsbury Volunteer Fire Co.green
conn · 1980 · cited in 1 Connecticut opinions naming this issue, 1992–1992
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 (22)

CaseCitedYears
Davenport v. Quinn green
connappct · 1999
2 sentences

2002We will address in turn the court’s application of each of these rules, mindful that both involve fact based determinations and that the ultimate “issue of whether the corporate veil [should be] pierced presents a question of fact”; id., 561 ; Davenport v. Quinn, 53 Conn. App. 282, 302 , 730 A.2d 1184 (1999); such that we must defer to the court’s findings unless they are clearly erroneous.

1999The instrumentality rule requires, in any case but an express agency, proof of three elements: (1) Control, not mere majority or complete stock control, but complete domination, not only of finances but of policy and business practice in respect to the transaction attacked so that the corporate entity as to this transaction had at the time no separate mind, will or existence of its own; (2) that such control must have been used by the defendant to commit fraud or wrong, to perpetrate the violation of a statutory or other positive legal duty, or a dishonest or unjust act in contravention of pla

61999–2002
Naples v. Keystone Building & Development Corp. green
conn · 2010
2 sentences

2019In assessing the first prong of the instrumentality rule, that is, whether an entity is dominated or controlled, courts consider a number of factors, including "(1) the absence of corporate formalities; (2) inadequate capitalization; (3) whether funds are put in and taken out of the corporation for personal rather than corporate purposes; (4) overlapping ownership, officers, directors, personnel; (5) common office space, address, phones; (6) the amount of business discretion by the allegedly dominated corporation; (7) whether the corporations dealt with each other at arm's length; (8) whether

2019In assessing the first prong of the instrumentality rule, that is, whether an entity is dominated or controlled, courts consider a number of factors, including "(1) the absence of corporate formalities; (2) inadequate capitalization; (3) whether funds are put in and taken out of the corporation for personal rather than corporate purposes; (4) overlapping ownership, officers, directors, personnel; (5) common office space, address, phones; (6) the amount of business discretion by the allegedly dominated corporation; (7) whether the corporations dealt with each other at arm's length; (8) whether

52012–2019
United Electrical Contractors, Inc. v. Progress Builders, Inc. green
connappct · 1992
2 sentences

1996Under CT Page 5114-QQ the instrumentality rule, in any case but that of express agency, proof of three elements is required: (1) Control, not mere majority or complete stock control, but complete domination, not only of the finances but of the policy and business practice in respect to the transaction attacked so that the corporate entity as to this transaction had at the time no separate mind, will or existence of its own; (2) that such control must have been used by the defendant to commit fraud or wrong, to perpetrate the violation of a statutory or other positive legal duty, or a dishonest

1996Under CT Page 5114-QQ the instrumentality rule, in any case but that of express agency, proof of three elements is required: (1) Control, not mere majority or complete stock control, but complete domination, not only of the finances but of the policy and business practice in respect to the transaction attacked so that the corporate entity as to this transaction had at the time no separate mind, will or existence of its own; (2) that such control must have been used by the defendant to commit fraud or wrong, to perpetrate the violation of a statutory or other positive legal duty, or a dishonest

31995–1996
Mountview Plaza Associates Inc. v. World Wide Pet Supply, Inc. green
connappct · 2003
2 sentences

2010The instrumentality rule requires, in any case but an express agency, proof of three elements: (1) Control, not mere majority or complete stock control, but complete domination, not only of finances but of policy and business practice in respect to the transaction attacked so that the coiporate entity as to this transaction had at the time no separate mind, will or existence of its own; (2) that such control must have been used by the defendant to commit fraud or wrong, to peipetrate the violation of a statutory or other positive legal duty, or a dishonest or unjust act in contravention of pla

2010The instrumentality rule requires, in any case but an express agency, proof of three elements: (1) Control, not mere majority or complete stock control, but complete domination, not only of finances but of policy and business practice in respect to the transaction attacked so that the coiporate entity as to this transaction had at the time no separate mind, will or existence of its own; (2) that such control must have been used by the defendant to commit fraud or wrong, to peipetrate the violation of a statutory or other positive legal duty, or a dishonest or unjust act in contravention of pla

22003–2010
Falcone v. Night Watchman, Inc. green
connappct · 1987
2 sentences

1993Under the instrumentality rule, in any case but that of express agency, proof of three elements is required: "`(1) Control, not mere majority or complete stock control, but complete domination, not only of finances but of policy and business practice in respect to the transaction attacked so that the corporate entity as to this transaction had at the time no separate mind, will or existence of its own; (2) that such control must have been used by the defendant to commit fraud or wrong, to perpetrate the violation of a statutory or other positive legal duty, or a dishonest or unjust act in cont

1993Under the instrumentality rule, in any case but that of express agency, proof of three elements is required: "`(1) Control, not mere majority or complete stock control, but complete domination, not only of finances but of policy and business practice in respect to the transaction attacked so that the corporate entity as to this transaction had at the time no separate mind, will or existence of its own; (2) that such control must have been used by the defendant to commit fraud or wrong, to perpetrate the violation of a statutory or other positive legal duty, or a dishonest or unjust act in cont

21990–1993
State v. Heller neutral
conn · 1967
2 sentences

1993Under the "identity" rule, as stated in Zaist v. Olson, 154 Conn. 563 , 576 , 227 A.2d 562 (1967), the corporate veil may be pierced when the plaintiff shows "`"such a unity of interest and ownership that the independence of the corporation had in effect ceased or had never begun, [and that] an adherence to the fiction of separate identity would serve only to defeat justice and equity by permitting the economic entity to escape liability arising out of an operation conducted by one corporation for the benefit of the whole enterprise.". . .'" (Citations omitted.) Falcone v. Night Watchman, Inc.

1992Under the “identity” rule, as stated in Zaist v. Olson, 154 Conn. 563, 576 , 227 A.2d 562 (1967), the corporate veil may be pierced when the plaintiff shows “ ‘ “such a unity of interest and ownership that the independence of the corporation had in effect ceased or had never begun, [and that] an adherence to the fiction of separate identity would serve only to defeat justice and equity by permitting the economic entity to escape liability arising out of an operation conducted by one corporation for the benefit of the whole enterprise.” . . .’ ” (Citations omitted.) Falcone v. Night Watchman, I

21992–1993
Bryan v. Sheraton Hartford Hotel green
conn · 2003
2 sentences

2019We are not persuaded. ‘‘It is well established that [t]he . . . determination of the proper legal standard in any given case is a question of law subject to our plenary review.’’ (Internal quotation marks omitted.) Mirjavadi v. Vakilzadeh, 310 Conn. 176 , 183, 74 A.3d 1278 (2013). ‘‘When determining whether piercing the corporate veil is proper, our Supreme Court has endorsed two tests: the instrumentality test and the identity test.’’7 (Internal quotation marks omitted.) KLM Industries, Inc. v. Tylutki, 75 Conn. App. 27, 32 , 815 A.2d 688 , cert. denied, 263 Conn. 916 , 821 A.2d 770 (2003).

2019We are not persuaded. ‘‘It is well established that [t]he . . . determination of the proper legal standard in any given case is a question of law subject to our plenary review.’’ (Internal quotation marks omitted.) Mirjavadi v. Vakilzadeh, 310 Conn. 176 , 183, 74 A.3d 1278 (2013). ‘‘When determining whether piercing the corporate veil is proper, our Supreme Court has endorsed two tests: the instrumentality test and the identity test.’’7 (Internal quotation marks omitted.) KLM Industries, Inc. v. Tylutki, 75 Conn. App. 27, 32 , 815 A.2d 688 , cert. denied, 263 Conn. 916 , 821 A.2d 770 (2003).

12019–2019
KLM Industries, Inc. v. Tylutki green
conn · 2003
2 sentences

2019We are not persuaded. ‘‘It is well established that [t]he . . . determination of the proper legal standard in any given case is a question of law subject to our plenary review.’’ (Internal quotation marks omitted.) Mirjavadi v. Vakilzadeh, 310 Conn. 176 , 183, 74 A.3d 1278 (2013). ‘‘When determining whether piercing the corporate veil is proper, our Supreme Court has endorsed two tests: the instrumentality test and the identity test.’’7 (Internal quotation marks omitted.) KLM Industries, Inc. v. Tylutki, 75 Conn. App. 27, 32 , 815 A.2d 688 , cert. denied, 263 Conn. 916 , 821 A.2d 770 (2003).

2019We are not persuaded. ‘‘It is well established that [t]he . . . determination of the proper legal standard in any given case is a question of law subject to our plenary review.’’ (Internal quotation marks omitted.) Mirjavadi v. Vakilzadeh, 310 Conn. 176 , 183, 74 A.3d 1278 (2013). ‘‘When determining whether piercing the corporate veil is proper, our Supreme Court has endorsed two tests: the instrumentality test and the identity test.’’7 (Internal quotation marks omitted.) KLM Industries, Inc. v. Tylutki, 75 Conn. App. 27, 32 , 815 A.2d 688 , cert. denied, 263 Conn. 916 , 821 A.2d 770 (2003).

12019–2019
KLM Industries, Inc. v. Tylutki green
connappct · 2003
2 sentences

2019We are not persuaded. ‘‘It is well established that [t]he . . . determination of the proper legal standard in any given case is a question of law subject to our plenary review.’’ (Internal quotation marks omitted.) Mirjavadi v. Vakilzadeh, 310 Conn. 176 , 183, 74 A.3d 1278 (2013). ‘‘When determining whether piercing the corporate veil is proper, our Supreme Court has endorsed two tests: the instrumentality test and the identity test.’’7 (Internal quotation marks omitted.) KLM Industries, Inc. v. Tylutki, 75 Conn. App. 27, 32 , 815 A.2d 688 , cert. denied, 263 Conn. 916 , 821 A.2d 770 (2003).

2019We are not persuaded. ‘‘It is well established that [t]he . . . determination of the proper legal standard in any given case is a question of law subject to our plenary review.’’ (Internal quotation marks omitted.) Mirjavadi v. Vakilzadeh, 310 Conn. 176 , 183, 74 A.3d 1278 (2013). ‘‘When determining whether piercing the corporate veil is proper, our Supreme Court has endorsed two tests: the instrumentality test and the identity test.’’7 (Internal quotation marks omitted.) KLM Industries, Inc. v. Tylutki, 75 Conn. App. 27, 32 , 815 A.2d 688 , cert. denied, 263 Conn. 916 , 821 A.2d 770 (2003).

12019–2019
Com'r of Env. Prot. v. State Five Indus. green
conn · 2012
2 sentences

2019There must be some wrong beyond the creditor's inability to collect, which is contrary to the creditor's rights, and that wrong must have proximately caused the inability to collect." (Citations omitted.) State Five , supra, 304 Conn. at 150 , 37 A.3d 724 .

2019There must be some wrong beyond the creditor's inability to collect, which is contrary to the creditor's rights, and that wrong must have proximately caused the inability to collect." (Citations omitted.) State Five , supra, 304 Conn. at 150 , 37 A.3d 724 .

12019–2019
Horenian v. Washington green
connappct · 2011
2 sentences

2012To the extent that the defendants do not dispute the court’s finding that the corporate veil of Tea House properly could be pierced under the identity rule, there is an unchallenged ground that supports the court’s decision. “[W]here alternative grounds found by the reviewing court and unchallenged on appeal would support the trial court’s judgment, independent of some challenged ground, the challenged ground that forms the basis of the appeal is moot because the court on appeal could grant no practical relief to the complainant.” (Internal quotation marks omitted.) Horenian v. Washington, 128

2012To the extent that the defendants do not dispute the court’s finding that the corporate veil of Tea House properly could be pierced under the identity rule, there is an unchallenged ground that supports the court’s decision. “[W]here alternative grounds found by the reviewing court and unchallenged on appeal would support the trial court’s judgment, independent of some challenged ground, the challenged ground that forms the basis of the appeal is moot because the court on appeal could grant no practical relief to the complainant.” (Internal quotation marks omitted.) Horenian v. Washington, 128

12012–2012
Hartford National Bank & Trust Co. v. DiFazio green
conn · 1979
2 sentences

2009Hartford National Bank & Trust Co. v. DiFazio, 177 Conn. 34 , 39 n.2, 411 A.2d 8 (1979). 5 Having determined that the court properly held the defendant liable under the instrumentality rule, we need not address the court’s alternate finding under the identity rule.

2009Hartford National Bank & Trust Co. v. DiFazio, 177 Conn. 34 , 39 n.2, 411 A.2d 8 (1979). 5 Having determined that the court properly held the defendant liable under the instrumentality rule, we need not address the court’s alternate finding under the identity rule.

12009–2009
Christian Brothers, Inc. v. South Windsor Arena, Inc. neutral
connappct · 1986
2 sentences

2002"The instrumentality rule requires, in any case but an express agency, proof of three elements: (1) Control, not mere majority or complete stock control, but complete domination, not only of finances but of policy and business practice in respect to the transaction attacked so that the corporate entity as to this transaction had at the time no separate mind, will or existence of its own; (2) that such control must have been used by the defendant to commit fraud or wrong, to perpetrate the violation of a statutory or other positive legal duty, or a dishonest or unjust act in contravention of pl

2002"The instrumentality rule requires, in any case but an express agency, proof of three elements: (1) Control, not mere majority or complete stock control, but complete domination, not only of finances but of policy and business practice in respect to the transaction attacked so that the corporate entity as to this transaction had at the time no separate mind, will or existence of its own; (2) that such control must have been used by the defendant to commit fraud or wrong, to perpetrate the violation of a statutory or other positive legal duty, or a dishonest or unjust act in contravention of pl

12002–2002
Standard Tallow Corp. v. Jowdy green
conn · 1983
1 sentence

1999McPheron v. Penn Central Transportation, Co., supra. Thus, it is inappropriate for the court in this proceeding to apply either the identity test or the instrumentality test.

11999–1999
MacChi v. Glow's Restaurant, Inc. green
conn · 1949
2 sentences

1996While not cited in those decisions, this court CT Page 3223 finds Macchi v. Glow's Restaurant, Inc. , 136 Conn. 156 , 69 A.2d 566 (1949), instructive.

1996While not cited in those decisions, this court CT Page 3223 finds Macchi v. Glow's Restaurant, Inc. , 136 Conn. 156 , 69 A.2d 566 (1949), instructive.

11996–1996
Mull v. Colt Co. green
nysd · 1962
11994–1994
Walkovszky v. Carlton green
nyappdiv · 1965
11994–1994
Klopp v. Thermal-Sash, Inc. green
connappct · 1987
11992–1992
Thompson v. United States green
dc · 1989
11992–1992
State v. Uretek, Inc. green
conn · 1988
11990–1990
Kulukundis v. Dean Stores Holding Co., Inc. green
conn · 1946
11989–1989
Vogel v. Town of New Milford green
conn · 1971
11989–1989

Statutes the citing opinions construe

CT § Conn. Gen. Stat. § 42-110a (11) CT § Conn. Gen. Stat. § 51-199 (6) CT § Conn. Gen. Stat. § 52-552e (6) CT § Conn. Gen. Stat. § 42-110b (5) CT § Conn. Gen. Stat. § 52-552a (5) CT § Conn. Gen. Stat. § 37-3a (3) CT § Conn. Gen. Stat. § 52-552 (3) CT § Conn. Gen. Stat. § 52-552f (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 65 (1987–2026) NC 39 (1966–2025) MS 8 (1993–2022) UT 8 (1994–2018) CA 7 (1965–2013) PA 7 (1974–2018) FL 6 (1976–2015) TN 6 (1979–2009) MI 4 (1984–2023) OH 4 (1996–2012) NY 4 (1936–2001) MD 4 (1995–1998) IL 3 (1996–2016) WA 3 (1975–1996) WV 3 (1937–2013) AL 3 (1997–2000) SC 2 (1996–1996) WI 2 (1988–1997) LA 2 (1986–1989) IN 2 (1976–2019)

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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