common-law collateral source rule (Connecticut) · Go Syfert
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common-law collateral source rule in Connecticut

8 Connecticut opinions name it 3 courts 1997–2021 1 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 (0)

CaseFollowedCited
No positive-treatment citations attached to this issue in Connecticut.

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 (10)

CaseCitedYears
Mack v. LaValley green
conn · 1999
2 sentences

2002In Mack v. LaValley, 55 Conn. App. 150, 167 , 738 A.2d 715 , cert. denied, 251 Conn. 928 , 742 A.2d 363 (1999), this court expressed its understanding of the common-law collateral source rule as follows: “Prior to the enactment of § 52-225a in 1985, Connecticut adhered to the common-law collateral source rule, which provides that ‘a defendant is not entitled to be relieved from paying any part of the compensation due for injuries proximately resulting from his act where payment [for such injuries or damages] comes from a collateral source, wholly independent of him.’ ” (Emphasis added.) In the

2002In Mack v. LaValley, 55 Conn. App. 150, 167 , 738 A.2d 715 , cert. denied, 251 Conn. 928 , 742 A.2d 363 (1999), this court expressed its understanding of the common-law collateral source rule as follows: “Prior to the enactment of § 52-225a in 1985, Connecticut adhered to the common-law collateral source rule, which provides that ‘a defendant is not entitled to be relieved from paying any part of the compensation due for injuries proximately resulting from his act where payment [for such injuries or damages] comes from a collateral source, wholly independent of him.’ ” (Emphasis added.) In the

22002–2021
Mack v. LaValley green
connappct · 1999
2 sentences

2021Mack v. LaValley, 55 Conn. App. 150, 167 , 738 A.2d 718 , cert. denied, 251 Conn. 928 , 742 A.2d 363 (1999).

2002In Mack v. LaValley, 55 Conn. App. 150, 167 , 738 A.2d 715 , cert. denied, 251 Conn. 928 , 742 A.2d 363 (1999), this court expressed its understanding of the common-law collateral source rule as follows: “Prior to the enactment of § 52-225a in 1985, Connecticut adhered to the common-law collateral source rule, which provides that ‘a defendant is not entitled to be relieved from paying any part of the compensation due for injuries proximately resulting from his act where payment [for such injuries or damages] comes from a collateral source, wholly independent of him.’ ” (Emphasis added.) In the

22002–2021
Rametta v. Stella green
conn · 1990
2 sentences

2006Under this rule, “a defendant is not entitled to be relieved from paying any part of the compensation due for injuries proximately resulting from his act where payment [for such injuries or damages] comes from a collateral source, wholly independent of him.” (Internal quotation marks omitted.) Rametta v. Stella, 214 Conn. 484, 489 , 572 A.2d 978 (1990).

2006Under this rule, “a defendant is not entitled to be relieved from paying any part of the compensation due for injuries proximately resulting from his act where payment [for such injuries or damages] comes from a collateral source, wholly independent of him.” (Internal quotation marks omitted.) Rametta v. Stella, 214 Conn. 484, 489 , 572 A.2d 978 (1990).

21999–2006
Brennan v. Burger King Corp. green
conn · 1998
2 sentences

1999The legislature abolished the common-law collateral source rule when it enacted § 52-225a (a), and “[i]t is a rule of statutory construction that statutes in derogation of the common law should be strictly construed so as not to exceed, modify or enlarge [their] provisions beyond [their] scope by the mechanics of statutory construction.” Brennan v. Burger King Corp., 46 Conn. App. 76, 82-83 , 698 A.2d 364 (1997), aff'd, 244 Conn. 204 , 707 A.2d 30 (1998).

1999The legislature abolished the common-law collateral source rule when it enacted § 52-225a (a), and “[i]t is a rule of statutory construction that statutes in derogation of the common law should be strictly construed so as not to exceed, modify or enlarge [their] provisions beyond [their] scope by the mechanics of statutory construction.” Brennan v. Burger King Corp., 46 Conn. App. 76, 82-83 , 698 A.2d 364 (1997), aff'd, 244 Conn. 204 , 707 A.2d 30 (1998).

21999–2002
Brennan v. Burger King Corp. neutral
connappct · 1997
2 sentences

1999The legislature abolished the common-law collateral source rule when it enacted § 52-225a (a), and “[i]t is a rule of statutory construction that statutes in derogation of the common law should be strictly construed so as not to exceed, modify or enlarge [their] provisions beyond [their] scope by the mechanics of statutory construction.” Brennan v. Burger King Corp., 46 Conn. App. 76, 82-83 , 698 A.2d 364 (1997), aff'd, 244 Conn. 204 , 707 A.2d 30 (1998).

1999The legislature abolished the common-law collateral source rule when it enacted § 52-225a (a), and “[i]t is a rule of statutory construction that statutes in derogation of the common law should be strictly construed so as not to exceed, modify or enlarge [their] provisions beyond [their] scope by the mechanics of statutory construction.” Brennan v. Burger King Corp., 46 Conn. App. 76, 82-83 , 698 A.2d 364 (1997), aff'd, 244 Conn. 204 , 707 A.2d 30 (1998).

21999–2002
Alvarado v. Black green
conn · 1999
2 sentences

2004See Jones v. Riley, supra, 263 Conn. 103 (noting § 52-225a abolished common-law collateral source rule in all personal injury actions); Alvarado v. Black, 248 Conn. 409, 417 , 728 A.2d 500 (1999) (same).

2004See Jones v. Riley, supra, 263 Conn. 103 (noting § 52-225a abolished common-law collateral source rule in all personal injury actions); Alvarado v. Black, 248 Conn. 409, 417 , 728 A.2d 500 (1999) (same).

12004–2004
Jones v. Kramer green
conn · 2004
2 sentences

2004The legislature enacted § 52-225a et seq., “in derogation of the common-law collateral source rule.” Jones v. Kramer, 267 Conn. 336, 348 , 838 A.2d 170 (2004).

2004The legislature enacted § 52-225a et seq., “in derogation of the common-law collateral source rule.” Jones v. Kramer, 267 Conn. 336, 348 , 838 A.2d 170 (2004).

12004–2004
Dime Savings Bank v. Arpaia green
connappct · 1999
1 sentence

2002In Mack v. LaValley, 55 Conn. App. 150, 167 , 738 A.2d 715 , cert. denied, 251 Conn. 928 , 742 A.2d 363 (1999), this court expressed its understanding of the common-law collateral source rule as follows: “Prior to the enactment of § 52-225a in 1985, Connecticut adhered to the common-law collateral source rule, which provides that ‘a defendant is not entitled to be relieved from paying any part of the compensation due for injuries proximately resulting from his act where payment [for such injuries or damages] comes from a collateral source, wholly independent of him.’ ” (Emphasis added.) In the

12002–2002
Nash v. Yap green
conn · 1999
2 sentences

1999The legislation reflects “the understanding that the entitlement of an injured party to be made whole does not include an entitlement to a double recovery for the same loss.” Nash v. Yap, 247 Conn. 638, 649 , 726 A.2d 92 (1999).

1999The legislation reflects “the understanding that the entitlement of an injured party to be made whole does not include an entitlement to a double recovery for the same loss.” Nash v. Yap, 247 Conn. 638, 649 , 726 A.2d 92 (1999).

11999–1999
Warner v. Leslie-Elliott Constructors, Inc. green
conn · 1984
2 sentences

1997Warner v. Leslie-Elliott Constructors, Inc., 194 Conn. 129, 133 , 479 A.2d 231 (1984).

1997Warner v. Leslie-Elliott Constructors, Inc., 194 Conn. 129, 133 , 479 A.2d 231 (1984).

11997–1997

Statutes the citing opinions construe

CT § Conn. Gen. Stat. § 52-572h (8) CT § Conn. Gen. Stat. § 52-225a (7) CT § Conn. Gen. Stat. § 52-225b (5)

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 8 (1997–2021) MN 6 (2003–2013) NJ 5 (1995–2020) FL 5 (1988–2015) AL 5 (2011–2025) KS 5 (1986–2009) MI 4 (1984–2016) OH 4 (2004–2013) NY 4 (1993–2024) TX 3 (2012–2013) MA 3 (2008–2015) OR 2 (2007–2019) WA 2 (1998–2001)

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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