veil-piercing doctrine (Connecticut) · Go Syfert
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veil-piercing doctrine in Connecticut

6 Connecticut opinions name it 2 courts 2012–2025 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 (2)

CaseFollowedCited
L. ROSS v. RW Roberts Const. Co.green
fladistctapp · 1985 · cited in 1 Connecticut opinions naming this issue, 2025–2025
1 sentence

2025Roberts Construction Co., 466 So. 2d 1096, 1098 (Fla. App. 1985) (statutory amendment providing for recovery of attorney’s fees for insureds who recover judgments against insurers was substantive because ‘‘[s]tatutes . . . which create a new right to attorney’s fees [create] a substantive right in favor of a limited class of potential plaintiffs (insureds) and a substantive burden or obligation upon a limited class of potential defendants (insurers)’’ (emphasis added; footnote omitted)).

11
Angelo Tomasso, Inc. v. Armor Construction & Paving, Inc.green
conn · 1982 · cited in 1 Connecticut opinions naming this issue, 2012–2012
2 sentences

2012Therefore, each case in which the issue is raised should be regarded as sui generis, to be decided in accordance with its own underlying facts." (Internal quotation marks omitted.) Angelo Tomasso, Inc. v. Armor Construction & Paving, Inc., 187 Conn. 544 , 556 n. 7, 447 A.2d 406 (1982).

2012Therefore, each case in which the issue is raised should be regarded as sui generis, to be decided in accordance with its own underlying facts." (Internal quotation marks omitted.) Angelo Tomasso, Inc. v. Armor Construction & Paving, Inc., 187 Conn. 544 , 556 n. 7, 447 A.2d 406 (1982).

11

Distinguished, questioned or overruled (1)

CaseNegativeCited
Unit Owners Ass'n of Summit Vista Lot 8 Condominium v. Millergreen
nh · 1996 · cited in 1 Connecticut opinions naming this issue, 2015–2015
2 sentences

2015J. 389, 408 n.110 (2008); but see Unit Owner’s Assn. of Summit Vista Lot 8 Condominium v. Miller, 141 N.H. 39, 44 , 677 A.2d 138 (1996) (holding that New Hampshire consumer protection statute ‘‘does not contain a specific provision that allows individuals to be held liable for the acts of the ‘corporate’ entity absent application of the veil- piercing doctrine’’). 12 As we have previously stated ‘‘in the absence of aggravating unscrupu- lous conduct, mere incompetence does not by itself mandate a trial court to find a CUTPA violation.’’ Naples v. Keystone Building & Development Corp., supra, 2

2015J. 389, 408 n.110 (2008); but see Unit Owner’s Assn. of Summit Vista Lot 8 Condominium v. Miller, 141 N.H. 39, 44 , 677 A.2d 138 (1996) (holding that New Hampshire consumer protection statute ‘‘does not contain a specific provision that allows individuals to be held liable for the acts of the ‘corporate’ entity absent application of the veil- piercing doctrine’’). 12 As we have previously stated ‘‘in the absence of aggravating unscrupu- lous conduct, mere incompetence does not by itself mandate a trial court to find a CUTPA violation.’’ Naples v. Keystone Building & Development Corp., supra, 2

11

Also cited on this issue (6)

CaseCitedYears
Zaist v. Olson green
conn · 1967
2 sentences

2019Connecticut first recognized traditional veil piercing claims, by which a court may disregard a corporate fiction to hold individual stockholders liable, in Zaist v. Olson, 154 Conn. 563 , 227 A.2d 552 (1967).

2019Connecticut first recognized traditional veil piercing claims, by which a court may disregard a corporate fiction to hold individual stockholders liable, in Zaist v. Olson, 154 Conn. 563 , 227 A.2d 552 (1967).

22019–2019
Shisler v. Sanfer Sports Cars, Inc. green
calctapp · 2008
2 sentences

2025Rather, given the complete lack of connection between that issue and the underlying substantive law governing the plaintiff’s veil piercing claim, we conclude that TCI’s fee shifting rule is not ‘‘so interwoven with the plaintiff’s cause of action as to be deemed substantive.’’ Gershon v. Back, supra, 346 Conn. 200 . e.g., Shisler v. Sanfer Sports Cars, Inc., 167 Cal. App. 4th 1, 11 , 83 Cal. Rptr. 3d 771 (2008) (Florida unfair trade practices statute providing for prevailing party attorney’s fees was substantive); BMW of North America, LLC v. Henry, 336 So. 3d 1255 , 1258 (Fla. App. 2022) (aw

2025Rather, given the complete lack of connection between that issue and the underlying substantive law governing the plaintiff’s veil piercing claim, we conclude that TCI’s fee shifting rule is not ‘‘so interwoven with the plaintiff’s cause of action as to be deemed substantive.’’ Gershon v. Back, supra, 346 Conn. 200 . e.g., Shisler v. Sanfer Sports Cars, Inc., 167 Cal. App. 4th 1, 11 , 83 Cal. Rptr. 3d 771 (2008) (Florida unfair trade practices statute providing for prevailing party attorney’s fees was substantive); BMW of North America, LLC v. Henry, 336 So. 3d 1255 , 1258 (Fla. App. 2022) (aw

12025–2025
BMW OF NORTH AMERICA, LLC vs MARIE LOUISE HENRY green
fladistctapp · 2022
1 sentence

2025Rather, given the complete lack of connection between that issue and the underlying substantive law governing the plaintiff’s veil piercing claim, we conclude that TCI’s fee shifting rule is not ‘‘so interwoven with the plaintiff’s cause of action as to be deemed substantive.’’ Gershon v. Back, supra, 346 Conn. 200 . e.g., Shisler v. Sanfer Sports Cars, Inc., 167 Cal. App. 4th 1, 11 , 83 Cal. Rptr. 3d 771 (2008) (Florida unfair trade practices statute providing for prevailing party attorney’s fees was substantive); BMW of North America, LLC v. Henry, 336 So. 3d 1255 , 1258 (Fla. App. 2022) (aw

12025–2025
Deutsche Bank AG v. Sebastian Holdings, Inc. green
connappct · 2017
2 sentences

2019The Appellate Court aptly noted that requiring the plaintiff to have pursued its veil piercing claim "in the English action would produce an unjust result, as the plaintiff would have been required to have anticipated that Sebastian would refuse to satisfy the English judgment." Id.

2019The Appellate Court determined that the plaintiff's veil piercing claim was not barred by the doctrine of res judicata because the plaintiff "is not seeking to relitigate a claim of contractual liability that previously was decided in the English judgment" but, rather, "to enforce the unsatisfied English judgment against Vik under a corporate veil piercing theory." Id., at 585 , 166 A.3d 716 .

12019–2019
C.F. Trust, Inc. v. First Flight Ltd. Partnership green
va · 2003
2 sentences

2019Trust, Inc. v. First Flight L.P. , supra, 266 Va. at 12 -13 , 580 S.E.2d 806 .

2019Trust, Inc. v. First Flight L.P. , supra, 266 Va. at 12 -13 , 580 S.E.2d 806 .

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

2019Trust, Inc. , in which that court applied the traditional veil piercing rule but additionally required that "a court considering reverse veil piercing ... weigh the impact of such action upon innocent investors ... [and] innocent secured and unsecured creditors ... [and] also consider the availability of *52 other remedies the creditor may pursue." (Internal quotation marks omitted.) State Five , supra, at 142 , 37 A.3d 724 , quoting C.F.

12019–2019

Statutes the citing opinions construe

CT § Conn. Gen. Stat. § 51-199 (4) CT § Conn. Gen. Stat. § 1-2z (3) CT § Conn. Gen. Stat. § 52-552 (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

NY 19 (2000–2026) IL 11 (2014–2026) CO 7 (2009–2024) CT 6 (2012–2025) TX 6 (2012–2017) NC 5 (2015–2025) PA 5 (2022–2026) DE 5 (2013–2024) AK 4 (2013–2025) MN 4 (2006–2018) GA 4 (2013–2019) MS 3 (2012–2026) NV 2 (2017–2017) OH 2 (2016–2023) OR 2 (2006–2006) MO 2 (2014–2014) MI 2 (2017–2017)

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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