expressio unius est exclusio alterius doctrine (Connecticut) · Go Syfert
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expressio unius est exclusio alterius doctrine in Connecticut

7 Connecticut opinions name it 2 courts 2011–2025 5 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 (3)

CaseFollowedCited
Biro v. Matzgreen
connappct · 2011 · cited in 1 Connecticut opinions naming this issue, 2024–2024
2 sentences

2024Our construction of the operative contract also is informed by the doctrine of expressio unius est exclusio alterius, meaning ‘‘the expression of one thing is the exclusion of another . . . .’’ (Internal quotation marks omitted.) Stratford Police Dept. v. Board of Firearms Permit Examiners, 343 Conn. 62, 74 , 272 A.3d 639 (2022); see also Biro v. Matz, 132 Conn. App. 272, 282 , 33 A.3d 742 (2011) (‘‘[l]ong a staple of our statutory interpretation, this court also has applied the principle [of expressio unius est exclusio alterius] to contractual agreements’’).

2024Our construction of the operative contract also is informed by the doctrine of expressio unius est exclusio alterius, meaning ‘‘the expression of one thing is the exclusion of another . . . .’’ (Internal quotation marks omitted.) Stratford Police Dept. v. Board of Firearms Permit Examiners, 343 Conn. 62, 74 , 272 A.3d 639 (2022); see also Biro v. Matz, 132 Conn. App. 272, 282 , 33 A.3d 742 (2011) (‘‘[l]ong a staple of our statutory interpretation, this court also has applied the principle [of expressio unius est exclusio alterius] to contractual agreements’’).

11
Commission on Human Rights & Opportunities v. Edge Fitness, LLCgreen
conn · 2022 · cited in 1 Connecticut opinions naming this issue, 2023–2023
1 sentence

2023See, e.g., Commission on Human Rights & Opportunities v. Edge Fitness, LLC, 342 Conn. 25, 36 , 268 A.3d 630 (2022); see also Borelli v. Renaldi, supra, 336 Conn. 109 (Ecker, J., dissenting) (citing doctrine of expressio unius est exclusio alterius and noting that ‘‘the legislature mani- festly paid very close attention to detail in fashioning subsection (b)’’).

11
Honulik v. Town of Greenwichgreen
conn · 2009 · cited in 1 Connecticut opinions naming this issue, 2011–2011
2 sentences

2011See Honulik v. Greenwich, 293 Conn. 641 , 694 n.5, 980 A.2d 845 (2009) (Zarella, J., dissenting) (“[w]hen the items expressed are members of an associated group or series, we may invoke the canon of statutory construction known as expressio unius est exclusio alterius . . . and infer that the item not mentioned . . . was excluded by deliberate choice” [internal quotation marks omitted]).

2011See Honulik v. Greenwich, 293 Conn. 641 , 694 n.5, 980 A.2d 845 (2009) (Zarella, J., dissenting) (“[w]hen the items expressed are members of an associated group or series, we may invoke the canon of statutory construction known as expressio unius est exclusio alterius . . . and infer that the item not mentioned . . . was excluded by deliberate choice” [internal quotation marks omitted]).

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 (3)

CaseCitedYears
Mayer v. Historic Dist. Comm'n of Groton green
conn · 2017
2 sentences

2025On appeal, however, the defendants attempt to pursue a different claim, arguing that, ‘‘[d]espite the ‘includes, but is not limited to’ language, the legislature’s deliberate exclusion of the definition of ‘mental disability’ while explicitly including the definition of ‘physical disability’ clearly indicates an intent that the definition of ‘mental disability’ in [§] 46a- 51 (20) does not apply to the phrase ‘physical or mental disability’ used in [§] 46a-64b.’’ They rely on ‘‘the doctrine of expressio unius est exclusio alterius—the expression of one thing is the exclusion of another—[under

2025On appeal, however, the defendants attempt to pursue a different claim, arguing that, ‘‘[d]espite the ‘includes, but is not limited to’ language, the legislature’s deliberate exclusion of the definition of ‘mental disability’ while explicitly including the definition of ‘physical disability’ clearly indicates an intent that the definition of ‘mental disability’ in [§] 46a- 51 (20) does not apply to the phrase ‘physical or mental disability’ used in [§] 46a-64b.’’ They rely on ‘‘the doctrine of expressio unius est exclusio alterius—the expression of one thing is the exclusion of another—[under

32022–2025
Stratford Police Dept. v. Board of Firearms Permit Examiners green
conn · 2022
1 sentence

2024Our construction of the operative contract also is informed by the doctrine of expressio unius est exclusio alterius, meaning ‘‘the expression of one thing is the exclusion of another . . . .’’ (Internal quotation marks omitted.) Stratford Police Dept. v. Board of Firearms Permit Examiners, 343 Conn. 62, 74 , 272 A.3d 639 (2022); see also Biro v. Matz, 132 Conn. App. 272, 282 , 33 A.3d 742 (2011) (‘‘[l]ong a staple of our statutory interpretation, this court also has applied the principle [of expressio unius est exclusio alterius] to contractual agreements’’).

12024–2024
State v. Bell green
conn · 2011
2 sentences

2016State v. Bell, 303 Conn. 246, 265 , 33 A.3d 167 (2011).

2016State v. Bell, 303 Conn. 246, 265 , 33 A.3d 167 (2011).

12016–2016

Statutes the citing opinions construe

CT § Conn. Gen. Stat. § 1-2z (6) CT § Conn. Gen. Stat. § 51-199 (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

MI 50 (1953–2025) NC 35 (1979–2026) CA 30 (1944–2025) TX 28 (1961–2021) WI 23 (1980–2023) PA 22 (2002–2026) FL 11 (1934–2021) AZ 8 (1967–2017) NY 7 (1931–2024) KS 7 (2001–2022) CT 7 (2011–2025) IL 6 (1983–2012) MD 5 (2004–2015) IN 5 (1989–2026) WA 5 (2000–2013) OH 4 (1969–2017) NM 4 (1935–2005) WV 4 (1949–2011) AR 3 (2010–2011) NJ 3 (1980–2001) MO 3 (1911–1983) ID 3 (1954–1991) GA 2 (1967–2005) WY 2 (1933–2013) DE 2 (1968–2024) NH 2 (2016–2022) CO 2 (2007–2008)

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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