subject matter jurisdiction requirement in Connecticut

2020The subject matter jurisdiction requirement may not be waived by any party, and also may be raised by a party, or by the court sua sponte, at any stage of the proceedings, including on appeal.’’ (Internal quotation marks omitted.)); Ajadi v. Commissioner of Correction, 280 Conn. 514, 535 , 911 A.2d 712 (2006) (‘‘a judgment rendered without subject matter jurisdiction is void’’); Selby v. Building Group, Inc., 129 Conn. App. 599, 603 , 19 A.3d 1289 (2011) (‘‘It is axiomatic that a court does not have personal jurisdiction over a nonparty.

2020The subject matter jurisdiction requirement may not be waived by any party, and also may be raised by a party, or by the court sua sponte, at any stage of the proceedings, including on appeal.’’ (Internal quotation marks omitted.)); Ajadi v. Commissioner of Correction, 280 Conn. 514, 535 , 911 A.2d 712 (2006) (‘‘a judgment rendered without subject matter jurisdiction is void’’); Selby v. Building Group, Inc., 129 Conn. App. 599, 603 , 19 A.3d 1289 (2011) (‘‘It is axiomatic that a court does not have personal jurisdiction over a nonparty.

2021The subject matter jurisdiction requirement may not be waived by any party, and also may be raised by a party, or by the court sua sponte, at any stage of the proceedings, including on appeal.’’ (Citations omitted; internal quotation marks omitted.) Peters v. Dept. of Social Services, 273 Conn. 434, 441 , 870 A.2d 448 (2005).

2021The subject matter jurisdiction requirement may not be waived by any party, and also may be raised by a party, or by the court sua sponte, at any stage of the proceedings, including on appeal.’’ (Citations omitted; internal quotation marks omitted.) Peters v. Dept. of Social Services, 273 Conn. 434, 441 , 870 A.2d 448 (2005).

2026The subject matter jurisdiction requirement may not be waived by any party, and also may be raised by a party, or by the court sua sponte, at any stage of the proceedings, including on appeal.” (Internal quotation marks omitted.) Sousa v. Sousa, 322 Conn. 757, 770 , 143 A.3d 578 (2016).

2026The subject matter jurisdiction requirement may not be waived by any party, and also may be raised by a party, or by the court sua sponte, at any stage of the proceedings, including on appeal.” (Internal quotation marks omitted.) Sousa v. Sousa, 322 Conn. 757, 770 , 143 A.3d 578 (2016).

2022The subject matter jurisdiction requirement may not be waived by any party, and also may be raised by a party, or by the court sua sponte, at any stage of the proceedings, including on appeal.’’ (Internal quotation marks omitted.) Richardson v. Commissioner of Correction, 298 Conn. 690, 696 , 6 A.3d 52 (2010).

2022The subject matter jurisdiction requirement may not be waived by any party, and also may be raised by a party, or by the court sua sponte, at any stage of the proceedings, including on appeal.’’ (Internal quotation marks omitted.) Richardson v. Commissioner of Correction, 298 Conn. 690, 696 , 6 A.3d 52 (2010).

2024The subject matter jurisdiction requirement may not be waived by any party, and also may be raised by a party, or by the court sua sponte, at any stage of the proceedings, including on appeal.’’ (Internal quotation marks omitted.) Gonzalez v. Commissioner of Correction, 107 Conn. App. 507, 511 , 946 0 Conn. App. 1 ,0 9 Commission on Human Rights & Opportunities v. Travelers Indemnity Co. A.2d 252, cert. denied, 289 Conn. 902 , 957 A.2d 870 (2008). 1 First, Travelers argues that ‘‘this case [was] moot and should [have been] dismissed’’ because it ‘‘long ago agreed to stop using the phrase ‘rece

2024The subject matter jurisdiction requirement may not be waived by any party, and also may be raised by a party, or by the court sua sponte, at any stage of the proceedings, including on appeal.’’ (Internal quotation marks omitted.) Gonzalez v. Commissioner of Correction, 107 Conn. App. 507, 511 , 946 0 Conn. App. 1 ,0 9 Commission on Human Rights & Opportunities v. Travelers Indemnity Co. A.2d 252, cert. denied, 289 Conn. 902 , 957 A.2d 870 (2008). 1 First, Travelers argues that ‘‘this case [was] moot and should [have been] dismissed’’ because it ‘‘long ago agreed to stop using the phrase ‘rece

2024The subject matter jurisdiction requirement may not be waived by any party, and also may be raised by a party, or by the court sua sponte, at any stage of the proceedings, including on appeal.’’ (Internal quotation marks omitted.) Gonzalez v. Commissioner of Correction, 107 Conn. App. 507, 511 , 946 0 Conn. App. 1 ,0 9 Commission on Human Rights & Opportunities v. Travelers Indemnity Co. A.2d 252, cert. denied, 289 Conn. 902 , 957 A.2d 870 (2008). 1 First, Travelers argues that ‘‘this case [was] moot and should [have been] dismissed’’ because it ‘‘long ago agreed to stop using the phrase ‘rece

2024The subject matter jurisdiction requirement may not be waived by any party, and also may be raised by a party, or by the court sua sponte, at any stage of the proceedings, including on appeal.’’ (Internal quotation marks omitted.) Gonzalez v. Commissioner of Correction, 107 Conn. App. 507, 511 , 946 228 Conn. App. 803 OCTOBER, 2024 9 Commission on Human Rights & Opportunities v. Travelers Indemnity Co. A.2d 252, cert. denied, 289 Conn. 902 , 957 A.2d 870 (2008). 1 First, Travelers argues that ‘‘this case [was] moot and should [have been] dismissed’’ because it ‘‘long ago agreed to stop using t

2017The subject matter jurisdiction requirement may not be waived by any party, and also may be raised by a party, or by the court sua sponte, at any stage of the proceed- ings, including on appeal.’’ (Internal quotation marks omitted.) Ajadi v. Commissioner of Correction, 280 Conn. 514 , 532–33, 911 A.2d 712 (2006). ‘‘A habeas court has subject matter jurisdiction to hear a petition for [a writ of] habeas corpus [if] the petitioner is in custody at the time that the habeas petition is filed.’’ Young v. Commissioner of Correction, 104 Conn. App. 188, 191 , 932 A.2d 467 (2007), cert. denied, 285 Co

2017The subject matter jurisdiction requirement may not be waived by any party, and also may be raised by a party, or by the court sua sponte, at any stage of the proceed- ings, including on appeal.’’ (Internal quotation marks omitted.) Ajadi v. Commissioner of Correction, 280 Conn. 514 , 532–33, 911 A.2d 712 (2006). ‘‘A habeas court has subject matter jurisdiction to hear a petition for [a writ of] habeas corpus [if] the petitioner is in custody at the time that the habeas petition is filed.’’ Young v. Commissioner of Correction, 104 Conn. App. 188, 191 , 932 A.2d 467 (2007), cert. denied, 285 Co

2017The subject matter jurisdiction requirement may not be waived by any party, and also may be raised by a party, or by the court sua sponte, at any stage of the proceed- ings, including on appeal.’’ (Internal quotation marks omitted.) Ajadi v. Commissioner of Correction, 280 Conn. 514 , 532–33, 911 A.2d 712 (2006). ‘‘A habeas court has subject matter jurisdiction to hear a petition for [a writ of] habeas corpus [if] the petitioner is in custody at the time that the habeas petition is filed.’’ Young v. Commissioner of Correction, 104 Conn. App. 188, 191 , 932 A.2d 467 (2007), cert. denied, 285 Co

2017The subject matter jurisdiction requirement may not be waived by any party, and also may be raised by a party, or by the court sua sponte, at any stage of the proceed- ings, including on appeal.’’ (Internal quotation marks omitted.) Ajadi v. Commissioner of Correction, 280 Conn. 514 , 532–33, 911 A.2d 712 (2006). ‘‘A habeas court has subject matter jurisdiction to hear a petition for [a writ of] habeas corpus [if] the petitioner is in custody at the time that the habeas petition is filed.’’ Young v. Commissioner of Correction, 104 Conn. App. 188, 191 , 932 A.2d 467 (2007), cert. denied, 285 Co

2015The subject matter jurisdiction requirement may not be waived by any party, and also may be raised by a party, or by the court sua sponte, at any stage of the proceedings, including on appeal.’’ (Citation omitted; internal quotation marks omitted.) Pine v. Dept. of Public Health, 100 Conn. App. 175 , 179–80, 917 A.2d 590 (2007).

2015The subject matter jurisdiction requirement may not be waived by any party, and also may be raised by a party, or by the court sua sponte, at any stage of the proceedings, including on appeal.’’ (Citation omitted; internal quotation marks omitted.) Pine v. Dept. of Public Health, 100 Conn. App. 175 , 179–80, 917 A.2d 590 (2007).

2017The subject matter jurisdiction requirement may not be waived by any party, and also may be raised by a party, or by the court sua sponte, at any stage of the proceedings, including on appeal." (Internal quotation marks omitted.) Fernandez v. Commissioner of Correction , 139 Conn.App. 173 , 177-78, 55 A.3d 588 (2012).

2017The subject matter jurisdiction requirement may not be waived by any party, and also may be raised by a party, or by the court sua sponte, at any stage of the proceedings, including on appeal." (Internal quotation marks omitted.) Fernandez v. Commissioner of Correction , 139 Conn.App. 173 , 177-78, 55 A.3d 588 (2012).

2022In determining whether a court has subject matter jurisdiction, however, we indulge every presumption in favor of jurisdiction.’’ (Citations omitted; internal quotation marks omitted.) Reinke v. Sing, 328 Conn. 376, 382 , 179 A.3d 769 (2018).

2022In determining whether a court has subject matter jurisdiction, however, we indulge every presumption in favor of jurisdiction.’’ (Citations omitted; internal quotation marks omitted.) Reinke v. Sing, 328 Conn. 376, 382 , 179 A.3d 769 (2018).

2019The subject matter jurisdiction requirement may not be waived by any party, and also may be raised by a party, or by the court sua sponte, at any stage of the proceedings, including on appeal." (Internal quotation marks omitted.) Pentland v. Commissioner of Correction , 176 Conn. App. 779 , 784-85, 169 A.3d 851 , cert. denied, 327 Conn. 978 , 174 A.3d 800 (2017). "[I]n order to invoke successfully the jurisdiction of the habeas court, a petitioner must allege an interest sufficient to give rise to habeas relief ....

2019The subject matter jurisdiction requirement may not be waived by any party, and also may be raised by a party, or by the court sua sponte, at any stage of the proceedings, including on appeal." (Internal quotation marks omitted.) Pentland v. Commissioner of Correction , 176 Conn. App. 779 , 784-85, 169 A.3d 851 , cert. denied, 327 Conn. 978 , 174 A.3d 800 (2017). "[I]n order to invoke successfully the jurisdiction of the habeas court, a petitioner must allege an interest sufficient to give rise to habeas relief ....

2019The subject matter jurisdiction requirement may not be waived by any party, and also may be raised by a party, or by the court sua sponte, at any stage of the proceedings, including on appeal.’’ (Citation omitted; internal quotation marks omitted.) Keller v. Beckenstein, 305 Conn. 523 , 531-32, 46 A.3d 102 (2012).

2019The subject matter jurisdiction requirement may not be waived by any party, and also may be raised by a party, or by the court sua sponte, at any stage of the proceedings, including on appeal.’’ (Citation omitted; internal quotation marks omitted.) Keller v. Beckenstein, 305 Conn. 523 , 531-32, 46 A.3d 102 (2012).

2019The subject matter jurisdiction requirement may not be waived by any party, and also may be raised by a party, or by the court sua sponte, at any stage of the proceedings, including on appeal." (Internal quotation marks omitted.) Pentland v. Commissioner of Correction , 176 Conn. App. 779 , 784-85, 169 A.3d 851 , cert. denied, 327 Conn. 978 , 174 A.3d 800 (2017). "[I]n order to invoke successfully the jurisdiction of the habeas court, a petitioner must allege an interest sufficient to give rise to habeas relief ....

2019The subject matter jurisdiction requirement may not be waived by any party, and also may be raised by a party, or by the court sua sponte, at any stage of the proceedings, including on appeal." (Internal quotation marks omitted.) Pentland v. Commissioner of Correction , 176 Conn. App. 779 , 784-85, 169 A.3d 851 , cert. denied, 327 Conn. 978 , 174 A.3d 800 (2017). "[I]n order to invoke successfully the jurisdiction of the habeas court, a petitioner must allege an interest sufficient to give rise to habeas relief ....

2018The subject matter jurisdiction requirement may not be waived by any party, and also may be raised by a party, or by the court sua sponte, at any stage of the proceedings, including on appeal." (Internal quotation marks omitted.) O'Reilly v. Valletta , 139 Conn. App. 208 , 212-13, 55 A.3d 583 (2012), cert. denied, 308 Conn. 914 , 61 A.3d 1101 (2013).

2018The subject matter jurisdiction requirement may not be waived by any party, and also may be raised by a party, or by the court sua sponte, at any stage of the proceedings, including on appeal." (Internal quotation marks omitted.) O'Reilly v. Valletta , 139 Conn. App. 208 , 212-13, 55 A.3d 583 (2012), cert. denied, 308 Conn. 914 , 61 A.3d 1101 (2013).

2016Taylor , 91 Conn.App. 788 , 791, 882 A.2d 682 , cert. denied, 276 Conn. 928 , 889 A.2d 819 (2005).

2016Taylor , 91 Conn.App. 788 , 791, 882 A.2d 682 , cert. denied, 276 Conn. 928 , 889 A.2d 819 (2005).

2016Taylor , 91 Conn.App. 788 , 791, 882 A.2d 682 , cert. denied, 276 Conn. 928 , 889 A.2d 819 (2005).

2016Taylor , 91 Conn.App. 788 , 791, 882 A.2d 682 , cert. denied, 276 Conn. 928 , 889 A.2d 819 (2005).

2026“Before addressing the applicability of the litigation privilege, [w]e begin our analysis with a review of [this] doctrine . . . as set forth in Simms v. Seaman, 308 Conn. 523 , 531-40, 69 A.3d 880 (2013).

2026“Before addressing the applicability of the litigation privilege, [w]e begin our analysis with a review of [this] doctrine . . . as set forth in Simms v. Seaman, 308 Conn. 523 , 531-40, 69 A.3d 880 (2013).

2025We decline to do so because adopting that position would require us to overrule our own precedent in Thibodeau v. American Baptist Churches of Connecticut, 120 Conn. App. 666 , 994 A.2d 212 , cert. denied, 298 Conn. 901 , 3 A.3d 74 (2010), a case in which this court affirmed the dismissal of an action for lack of subject matter jurisdiction on first amendment establishment clause grounds; id., 667-68; and in which our Supreme Court denied certification to appeal.

2025We decline to do so because adopting that position would require us to overrule our own precedent in Thibodeau v. American Baptist Churches of Connecticut, 120 Conn. App. 666 , 994 A.2d 212 , cert. denied, 298 Conn. 901 , 3 A.3d 74 (2010), a case in which this court affirmed the dismissal of an action for lack of subject matter jurisdiction on first amendment establishment clause grounds; id., 667-68; and in which our Supreme Court denied certification to appeal.

2025We decline to do so because adopting that position would require us to overrule our own precedent in Thibodeau v. American Baptist Churches of Connecticut, 120 Conn. App. 666 , 994 A.2d 212 , cert. denied, 298 Conn. 901 , 3 A.3d 74 (2010), a case in which this court affirmed the dismissal of an action for lack of subject matter jurisdiction on first amendment establishment clause grounds; id., 667-68; and in which our Supreme Court denied certification to appeal.

2025We decline to do so because adopting that position would require us to overrule our own precedent in Thibodeau v. American Baptist Churches of Connecticut, 120 Conn. App. 666 , 994 A.2d 212 , cert. denied, 298 Conn. 901 , 3 A.3d 74 (2010), a case in which this court affirmed the dismissal of an action for lack of subject matter jurisdiction on first amendment establishment clause grounds; id., 667-68; and in which our Supreme Court denied certification to appeal.

2024The subject matter jurisdiction requirement may not be waived by any party, and also may be raised by a party, or by the court sua sponte, at any stage of the proceedings, including on appeal.’’ (Internal quotation marks omitted.) Sousa v. Sousa, 322 Conn. 757, 770 , 143 A.3d 578 (2016). ‘‘Subject matter jurisdiction does not rest on the via- bility of the claims that a court is asked to adjudicate.’’ (Internal quotation marks omitted.) State v. Fairchild, 155 Conn. App. 196 , 206, 108 A.3d 1162 , cert. denied, 316 Conn. 902 , 111 A.3d 470 (2015). ‘‘Subject matter jurisdiction involves the aut

2024The subject matter jurisdiction requirement may not be waived by any party, and also may be raised by a party, or by the court sua sponte, at any stage of the proceedings, including on appeal.’’ (Internal quotation marks omitted.) Sousa v. Sousa, 322 Conn. 757, 770 , 143 A.3d 578 (2016). ‘‘Subject matter jurisdiction does not rest on the via- bility of the claims that a court is asked to adjudicate.’’ (Internal quotation marks omitted.) State v. Fairchild, 155 Conn. App. 196 , 206, 108 A.3d 1162 , cert. denied, 316 Conn. 902 , 111 A.3d 470 (2015). ‘‘Subject matter jurisdiction involves the aut

2022We next set forth the relevant legal principles that govern our review of this claim. ‘‘It is well established that, for a court to have jurisdiction to entertain a habeas petition seeking to challenge the legality of a criminal conviction, the petitioner must be in the custody of the respondent as the result of that conviction at the time that the petition is filed.’’ (Emphasis in original.) Goguen v. Commissioner of Correction, 341 Conn. 508, 528 , 267 A.3d 831 (2021).

2022We next set forth the relevant legal principles that govern our review of this claim. ‘‘It is well established that, for a court to have jurisdiction to entertain a habeas petition seeking to challenge the legality of a criminal conviction, the petitioner must be in the custody of the respondent as the result of that conviction at the time that the petition is filed.’’ (Emphasis in original.) Goguen v. Commissioner of Correction, 341 Conn. 508, 528 , 267 A.3d 831 (2021).

2020The subject matter jurisdiction requirement may not be waived by any party, and also may be raised by a party, or by the court sua sponte, at any stage of the proceedings, including on appeal. . . . [S]ubject matter jurisdiction involves the authority of the court to adjudicate the type of controversy presented by the action before it . . . and a judgment rendered without subject matter jurisdiction is void.’’ (Citation omitted; internal quotation marks omitted.) Labissoniere v. Gaylord Hospital, Inc., 199 Conn. App. 265 , 275-76, A.3d (2020); Petrucelli v. Meriden, 198 Conn. App. 838, 846 , A

2020The subject matter jurisdiction requirement may not be waived by any party, and also may be raised by a party, or by the court sua sponte, at any stage of the proceedings, including on appeal. . . . [S]ubject matter jurisdiction involves the authority of the court to adjudicate the type of controversy presented by the action before it . . . and a judgment rendered without subject matter jurisdiction is void.’’ (Citation omitted; internal quotation marks omitted.) Labissoniere v. Gaylord Hospital, Inc., 199 Conn. App. 265 , 275-76, A.3d (2020); Petrucelli v. Meriden, 198 Conn. App. 838, 846 , A

2020The subject matter jurisdiction requirement may not be waived by any party, and also may be raised by a party, or by the court sua sponte, at any stage of the proceedings, including on appeal.’’7 (Internal quotation marks omitted.) In re Probate Appeal of Knott, 190 Conn. App. 56, 61 , 209 A.3d 690 (2019). ‘‘[W]ith respect to administrative appeals generally, there is no absolute right of appeal to the courts from a decision of an administrative [body]. . . .

2020The subject matter jurisdiction requirement may not be waived by any party, and also may be raised by a party, or by the court sua sponte, at any stage of the proceedings, including on appeal.’’7 (Internal quotation marks omitted.) In re Probate Appeal of Knott, 190 Conn. App. 56, 61 , 209 A.3d 690 (2019). ‘‘[W]ith respect to administrative appeals generally, there is no absolute right of appeal to the courts from a decision of an administrative [body]. . . .

2020If a court lacks jurisdiction over a person . . . the court has no authority to award a judgment against that person . . . .’’ (Internal quotation marks omitted.)); Angiolillo v. Buckmiller, 102 Conn. App. 697, 713 , 927 A.2d 312 (‘‘[i]f a court has never acquired jurisdiction over a defendant or the subject matter . . . any judgment ultimately entered is void and subject to vacation or collateral attack’’ (internal quotation marks omitted)), cert. denied, 284 Conn. 927 , 934 A.2d 243 (2007); Bicio v. Brewer, supra, 92 Conn. App. 167 (same).

2020If a court lacks jurisdiction over a person . . . the court has no authority to award a judgment against that person . . . .’’ (Internal quotation marks omitted.)); Angiolillo v. Buckmiller, 102 Conn. App. 697, 713 , 927 A.2d 312 (‘‘[i]f a court has never acquired jurisdiction over a defendant or the subject matter . . . any judgment ultimately entered is void and subject to vacation or collateral attack’’ (internal quotation marks omitted)), cert. denied, 284 Conn. 927 , 934 A.2d 243 (2007); Bicio v. Brewer, supra, 92 Conn. App. 167 (same).

2020The subject matter jurisdiction requirement may not be waived by any party, and also may be raised by a party, or by the court sua sponte, at any stage of the proceedings, including on appeal.’’ (Internal quotation marks omitted.)); Ajadi v. Commissioner of Correction, 280 Conn. 514, 535 , 911 A.2d 712 (2006) (‘‘a judgment rendered without subject matter jurisdiction is void’’); Selby v. Building Group, Inc., 129 Conn. App. 599, 603 , 19 A.3d 1289 (2011) (‘‘It is axiomatic that a court does not have personal jurisdiction over a nonparty.

2020The subject matter jurisdiction requirement may not be waived by any party, and also may be raised by a party, or by the court sua sponte, at any stage of the proceedings, including on appeal.’’ (Internal quotation marks omitted.)); Ajadi v. Commissioner of Correction, 280 Conn. 514, 535 , 911 A.2d 712 (2006) (‘‘a judgment rendered without subject matter jurisdiction is void’’); Selby v. Building Group, Inc., 129 Conn. App. 599, 603 , 19 A.3d 1289 (2011) (‘‘It is axiomatic that a court does not have personal jurisdiction over a nonparty.

2020The subject matter jurisdiction requirement may not be waived by any party, and also may be raised by a party, or by the court sua sponte, at any stage of the proceedings, including on appeal.’’ (Internal quotation marks omitted.) Id. ‘‘[S]ubject matter jurisdiction involves the authority of the court to adjudicate the type of controversy presented by the action before it . . . and a judgment rendered without subject matter jurisdiction is void.’’ (Internal quotation marks omitted.) Bruno v. Travelers Cos., 172 Conn. App. 717, 724 , 161 A.3d 630 (2017).