proximate cause standard (Connecticut) · Go Syfert
← Connecticut issues

proximate cause standard in Connecticut

48 Connecticut opinions name it 3 courts 1967–2020 0 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
White v. Burnsgreen
conn · 1990 · cited in 8 Connecticut opinions naming this issue, 1990–2012
2 sentences

2006We conclude, however, that such a broad exception to the sole proximate cause doctrine would render the doctrine useless in numerous instances and would constitute a sub silentio overruling of our Supreme Court’s decision in White v. Burns, supra, 213 Conn. 307 , which, as indicated, is not within the province of this court. *103 In reaching that conclusion, we need look only so far as the decisions of this court and our Supreme Court, decided both before and after White v. Burns, supra, 307 , in which it was determined that the plaintiffs had failed to prove that the challenged highway defect

1995Recently, in White v. Burns, 213 Conn. 307, 336 , 567 A.2d 1195 (1990), our Supreme Court reviewed this area of the law and concluded that “[s]ole proximate cause remains the standard of causation under § 13a-144.” The plaintiff claims, however, that Zeidwig v. Derby, supra, 129 Conn. 693 , created an exception to the sole proximate cause standard under § 13a-144.

48
Smith v. City of New Havengreen
conn · 2001 · cited in 4 Connecticut opinions naming this issue, 2001–2013
2 sentences

2013If the negligence of himself or of a third person is also a proximate cause, he cannot say with truth that he was injured by the defect; [the plaintiff] can only say with truth that he was injured by his own or another’s carelessness and the defect, and the two combined give no cause of action under the statute.’ ” (Citation omitted; emphasis in original.) Smith v. New Haven, 258 Conn. 56, 61-62 , 779 A.2d 104 (2001) “Thus, from the inception of the sole proximate cause doctrine, we have embraced the notion that a municipality’s liability under the defective highway statute may be defeated by

2013If the negligence of himself or of a third person is also a proximate cause, he cannot say with truth that he was injured by the defect; [the plaintiff] can only say with truth that he was injured by his own or another’s carelessness and the defect, and the two combined give no cause of action under the statute.’ ” (Citation omitted; emphasis in original.) Smith v. New Haven, 258 Conn. 56, 61-62 , 779 A.2d 104 (2001) “Thus, from the inception of the sole proximate cause doctrine, we have embraced the notion that a municipality’s liability under the defective highway statute may be defeated by

24
Williamson v. Commissioner of Transportationgreen
conn · 1988 · cited in 4 Connecticut opinions naming this issue, 1990–1997
2 sentences

1995“The incorporation of the sole proximate cause requirement for actions brought under the state defective highway statute dates back to Perrotti v. Bennett, 94 Conn. 533 , 109 A. 890 (1920).” Williamson v. Commissioner of Transportation, 209 Conn. 310, 317 , 551 A.2d 704 (1988).

1995“The incorporation of the sole proximate cause requirement for actions brought under the state defective highway statute dates back to Perrotti v. Bennett, 94 Conn. 533 , 109 A. 890 (1920).” Williamson v. Commissioner of Transportation, 209 Conn. 310, 317 , 551 A.2d 704 (1988).

24
Sanzone v. Board of Police Commissionersgreen
conn · 1991 · cited in 2 Connecticut opinions naming this issue, 1993–2001
2 sentences

2001See Sanzone v. Board of Police Commissioners, 219 Conn. 179, 197 , 592 A.2d 912 (1991) (“[§] 13a-149 does not permit recovery unless the defect was the sole proximate cause of the injury, even if the concurring cause was a third party’s negligence”); Roth v. MacDonald, 124 Conn. 461, 463 , 200 A. 725 (1938) (driver’s negligence was contributing factor to accident, relieving municipality of liability for passengers’ injuries); Messina v. New Haven, 119 Conn. 166, 168 , 174 A. 188 (1934) (“when an injury results from a defect combined with the culpable negligence of a third party it cannot be sa

2001See Sanzone v. Board of Police Commissioners, 219 Conn. 179, 197 , 592 A.2d 912 (1991) (“[§] 13a-149 does not permit recovery unless the defect was the sole proximate cause of the injury, even if the concurring cause was a third party’s negligence”); Roth v. MacDonald, 124 Conn. 461, 463 , 200 A. 725 (1938) (driver’s negligence was contributing factor to accident, relieving municipality of liability for passengers’ injuries); Messina v. New Haven, 119 Conn. 166, 168 , 174 A. 188 (1934) (“when an injury results from a defect combined with the culpable negligence of a third party it cannot be sa

22
Barry v. Quality Steel Products, Inc.green
conn · 2003 · cited in 7 Connecticut opinions naming this issue, 2006–2019
2 sentences

2019In light of the significant changes to our tort system implemented by tort reform, however, this court determined in Barry "that the doctrine of superseding cause no longer serves a useful purpose in our jurisprudence when a defendant claims that a subsequent negligent act by a third party cuts off its own liability for the plaintiff's injuries. [In such] circumstances, superseding cause instructions serve to complicate what is fundamentally a proximate cause analysis.... [B]ecause our statutes allow for apportionment among negligent defendants; see General Statutes § 52-572h ; and because Con

2019In light of the significant changes to our tort system implemented by tort reform, however, this court determined in Barry "that the doctrine of superseding cause no longer serves a useful purpose in our jurisprudence when a defendant claims that a subsequent negligent act by a third party cuts off its own liability for the plaintiff's injuries. [In such] circumstances, superseding cause instructions serve to complicate what is fundamentally a proximate cause analysis.... [B]ecause our statutes allow for apportionment among negligent defendants; see General Statutes § 52-572h ; and because Con

17
Perrotti v. Bennettgreen
· 1920 · cited in 5 Connecticut opinions naming this issue, 1988–2009
2 sentences

2006Summary judgment was rendered in favor of those entities on counts four and five on the ground that the plaintiff had not provided any expert who would testily that the work had been performed below the standard of care required or that any such work negligently performed was the proximate cause of the collision. 6 Although the plaintiff opposed the defendant’s motion for summary judgment, he did not claim that there were any factual issues in dispute. 7 The sole proximate cause doctrine, which was applied first to municipal highways in Bartram v. Sharon, supra, 71 Conn. 686 , was extended to

2006Summary judgment was rendered in favor of those entities on counts four and five on the ground that the plaintiff had not provided any expert who would testily that the work had been performed below the standard of care required or that any such work negligently performed was the proximate cause of the collision. 6 Although the plaintiff opposed the defendant’s motion for summary judgment, he did not claim that there were any factual issues in dispute. 7 The sole proximate cause doctrine, which was applied first to municipal highways in Bartram v. Sharon, supra, 71 Conn. 686 , was extended to

15
Bartram v. Town of Sharongreen
conn · 1899 · cited in 5 Connecticut opinions naming this issue, 1997–2009
2 sentences

2009Our Supreme Court first identified the sole proximate cause standard for determining municipal liability under the predecessor to § 13a-149 in Bartram v. Sharon, 71 Conn. 686, 690 , 43 A. 143 (1899).

2009Our Supreme Court first identified the sole proximate cause standard for determining municipal liability under the predecessor to § 13a-149 in Bartram v. Sharon, 71 Conn. 686, 690 , 43 A. 143 (1899).

15
Kolich v. Shugruegreen
conn · 1986 · cited in 3 Connecticut opinions naming this issue, 1990–2006
2 sentences

2006See, e.g., Kolich v. Shugrue, 198 Conn. 322 , 502 A.2d 918 (1986) (plaintiff claimed improperly secured guardrail was substantial factor in injuries also caused by intoxicated third party driver and could not prevail under defective highway statute requiring highway defect to be sole proximate cause of injuries); Sirot v. Burns, 37 Conn. App. 551 , 657 A.2d 681 (when plaintiff failed to prove third party free of negligence, plaintiff could not prevail on claim that defective median barrier was sole proximate cause of injuries), cert. denied, 234 Conn. 908 , 659 A.2d 1209 (1995); Roy v. Michaud

2006See, e.g., Kolich v. Shugrue, 198 Conn. 322 , 502 A.2d 918 (1986) (plaintiff claimed improperly secured guardrail was substantial factor in injuries also caused by intoxicated third party driver and could not prevail under defective highway statute requiring highway defect to be sole proximate cause of injuries); Sirot v. Burns, 37 Conn. App. 551 , 657 A.2d 681 (when plaintiff failed to prove third party free of negligence, plaintiff could not prevail on claim that defective median barrier was sole proximate cause of injuries), cert. denied, 234 Conn. 908 , 659 A.2d 1209 (1995); Roy v. Michaud

13
MacHado v. City of Hartfordgreen
conn · 2009 · cited in 2 Connecticut opinions naming this issue, 2009–2012
2 sentences

2012This argument misunderstands the implication of the sole proximate cause requirement, as recently clarified in Machado v. Hartford, supra, 292 Conn. at 379 , 972 A.2d 724 .

2012This argument misunderstands the implication of the sole proximate cause requirement, as recently clarified in Machado v. Hartford, supra, 292 Conn. at 379 , 972 A.2d 724 .

12
Lukas v. City of New Havengreen
conn · 1981 · cited in 2 Connecticut opinions naming this issue, 1990–2009
2 sentences

2009“It is settled law in this state that the liability of [a town] under § 13a-149 is purely for breach of a statutory duty and does not arise from negligence.” Lukas v. New Haven, 184 Conn. 205, 212 , 439 A.2d 949 (1981).

2009“It is settled law in this state that the liability of [a town] under § 13a-149 is purely for breach of a statutory duty and does not arise from negligence.” Lukas v. New Haven, 184 Conn. 205, 212 , 439 A.2d 949 (1981).

12
Vacco v. Microsoft Corp.green
conn · 2002 · cited in 1 Connecticut opinions naming this issue, 2019–2019
2 sentences

2019See Vacco v. Microsoft Corp. , supra, 260 Conn. at 90 -92 , 793 A.2d 1048 .

2019See Vacco v. Microsoft Corp. , supra, 260 Conn. at 90 -92 , 793 A.2d 1048 .

11
Labadie v. Norwalk Rehabilitation Services, Inc.green
conn · 2005 · cited in 1 Connecticut opinions naming this issue, 2011–2011
1 sentence

2011See Labadie v. Norwalk Rehabilitation Services, Inc., 274 Conn. 219, 237-38 , 875 A.2d485 (2005); Voronuk v. Electric Boat Corp., 118 Conn. App. 248, 253 , 982 A.2d 650 (2009); Hummel v. Marten Transport, Ltd., 114 Conn. App. 822, 844 , 970 A.2d 834 , cert. denied, 293 Conn. 907 , 978 A.2d 1109 (2009). 11 We note again that, although the parties entered into an agreement in June, 2006, the plaintiff failed to accept the agreements offered by the employer regarding the maximum medical improvement and 10 percent permanent partial disability rating of the plaintiffs brain. 12 Although both the co

11
Angelillo v. City of Meridengreen
conn · 1950 · cited in 1 Connecticut opinions naming this issue, 2009–2009
11
Mahoney v. Beatmangreen
· 1929 · cited in 1 Connecticut opinions naming this issue, 2008–2008
11
Catz v. Rubensteingreen
conn · 1986 · cited in 1 Connecticut opinions naming this issue, 1989–1989
11
Warner v. Liimatainengreen
conn · 1965 · cited in 1 Connecticut opinions naming this issue, 1967–1967
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 (64)

CaseCitedYears
Merhi v. Becker green
conn · 1973
2 sentences

1996The "substantial factor" test reflects the inquiry fundamental to all proximate cause questions, "`whether the harm which occurred was of the same general nature CT Page 7209 as the foreseeable risk created by the defendant's negligence.' Merhi v. Becker , 164 Conn. 516 , 521 , (1973))".

1996The "substantial factor" test, in truth, reflects the inquiry fundamental to all proximate cause questions; that is, "`whether the harm which occurred was of the same general nature as the foreseeable risk created by the defendant's negligence.' Merhi v. Becker, 164 Conn. 516 , 521 , 325 A.2d 270 (1973); see Palsgraf v. Long Island R.R.

41989–1996
Messina v. City of New Haven neutral
conn · 1934
2 sentences

2013See Sanzone v. Board of Police Commissioners, [supra, 219 Conn. 197 ] (‘[§] 13a-149 does not permit recovery unless the defect was the sole proximate cause of the injury, even if the concurring cause was a third party’s negligence’); Roth v. MacDonald, 124 Conn. 461, 463 , 200 A. 725 (1938) (driver’s negligence was contributing factor to accident, relieving municipality of liability for passengers’ injuries); Messina v. New Haven, 119 Conn. 166, 168 , 174 A. 188 (1934) (‘when an injury results from a defect combined with the culpable negligence of a third party it cannot be said to have been c

2013See Sanzone v. Board of Police Commissioners, [supra, 219 Conn. 197 ] (‘[§] 13a-149 does not permit recovery unless the defect was the sole proximate cause of the injury, even if the concurring cause was a third party’s negligence’); Roth v. MacDonald, 124 Conn. 461, 463 , 200 A. 725 (1938) (driver’s negligence was contributing factor to accident, relieving municipality of liability for passengers’ injuries); Messina v. New Haven, 119 Conn. 166, 168 , 174 A. 188 (1934) (‘when an injury results from a defect combined with the culpable negligence of a third party it cannot be said to have been c

22001–2013
Roth v. MacDonald green
conn · 1938
2 sentences

2013See Sanzone v. Board of Police Commissioners, [supra, 219 Conn. 197 ] (‘[§] 13a-149 does not permit recovery unless the defect was the sole proximate cause of the injury, even if the concurring cause was a third party’s negligence’); Roth v. MacDonald, 124 Conn. 461, 463 , 200 A. 725 (1938) (driver’s negligence was contributing factor to accident, relieving municipality of liability for passengers’ injuries); Messina v. New Haven, 119 Conn. 166, 168 , 174 A. 188 (1934) (‘when an injury results from a defect combined with the culpable negligence of a third party it cannot be said to have been c

2013See Sanzone v. Board of Police Commissioners, [supra, 219 Conn. 197 ] (‘[§] 13a-149 does not permit recovery unless the defect was the sole proximate cause of the injury, even if the concurring cause was a third party’s negligence’); Roth v. MacDonald, 124 Conn. 461, 463 , 200 A. 725 (1938) (driver’s negligence was contributing factor to accident, relieving municipality of liability for passengers’ injuries); Messina v. New Haven, 119 Conn. 166, 168 , 174 A. 188 (1934) (‘when an injury results from a defect combined with the culpable negligence of a third party it cannot be said to have been c

22001–2013
Coburn v. Lenox Homes, Inc. green
conn · 1982
2 sentences

2011Our Supreme Court has defined proximate cause “as [a]n actual cause that is a substantial factor in the resulting harm . . . .” Coburn v. Lenox Homes, Inc., 186 Conn. 370, 383 , 441 A.2d 620 (1982). “[T]he test of *157 proximate cause is whether the defendant’s conduct is a substantial factor in bringing about the plaintiffs injuries.” (Internal quotation marks omitted.) Paige v. St.

2011Our Supreme Court has defined proximate cause “as [a]n actual cause that is a substantial factor in the resulting harm . . . .” Coburn v. Lenox Homes, Inc., 186 Conn. 370, 383 , 441 A.2d 620 (1982). “[T]he test of *157 proximate cause is whether the defendant’s conduct is a substantial factor in bringing about the plaintiffs injuries.” (Internal quotation marks omitted.) Paige v. St.

21993–2011
Wei Ping Wu v. Town of Fairfield green
conn · 1987
2 sentences

1999"An essential element of any negligence action is the establishment of the defendant's conduct as a proximate cause of the plaintiff's injury." Wu v. Fairfield , 204 Conn. 435 , 438 , 528 A.2d 364 (1987).

1999"An essential element of any negligence action is the establishment of the defendant's conduct as a proximate cause of the plaintiff's injury." Wu v. Fairfield , 204 Conn. 435 , 438 , 528 A.2d 364 (1987).

21997–1999
Bioski v. Castelano, No. 0115265 (Mar. 21, 1995) green
connsuperct · 1995
2 sentences

1999"As the court in Nolan instructs, the cause of action for negligent supervision, in order to avoid the limitations imposed by the effect of the doctrine of proximate cause, must not be predicated on the furnishing of alcohol." Bloski v. Castelano, Superior Court, judicial district of Waterbury, Docket No. 115265 (Mar. 21, 1995, Flynn, J.) ( 14 Conn. L.

1996In such a situation, a patron or business visitor of the establishment who sustained an injury in person or property as a consequence of such negligence in supervision might have a common-law cause of action under the rule of cases such as Lowthert v. Loyal Order of Moose of Stamford Lodge 940 Inc. , 147 Conn. 529 , 533 , 163 A.2d 106 ." "As the court in Nolan instructs, the cause of action for negligent supervision, in order to avoid the limitations imposed by the effect of the doctrine of proximate cause, must not be predicated on the furnishing of alcohol." Bloski v. Castelano , Superior Co

21996–1999
Comba v. Town of Ridgefield green
conn · 1979
2 sentences

1997See , e.g., Williamson v. Commissioner , 209 Conn. 310 (1988); Kolich v. Shugrue , 198 Conn. 322 (1986); Comba v. Ridgefield , 177 Conn. 268 (1979); Tuckel v. Argroves , 148 Conn. 366 (1961).

1990See, e.g., Williamson v. Commissioner, 209 Conn. 310 , 551 A.2d 704 (1988); Lamb v. Burns, supra; Kolich v. Shugrue, 198 Conn. 322 , 502 A.2d 918 (1986); Comba v. Ridgefield, 177 Conn. 268 , 413 A.2d 859 (1979); Donnelly v. Ives, 159 Conn. 163 , 268 A.2d 406 (1970); Murphy v. Ives, supra; Tuckel v. Argraves, 148 Conn. 355 , 170 A.2d 895 (1961); Rapid Motor Lines, Inc. v. Cox, 134 Conn. 235 , 56 A.2d 519 (1947).

21990–1997
Ward v. Ramsey green
connappct · 2013
2 sentences

2020The existence of the proximate cause of an injury is determined by looking from the injury to the negligent act complained of for the necessary causal connection. . . . ‘‘In other words, [p]roximate cause [is] defined as an actual cause that is a substantial factor in the resulting harm . . . . [T]he inquiry fundamental to all proximate cause questions . . . [is] whether the harm which occurred was of the same general nature as the foresee- able risk created by the defendant’s negligence.’’ (Cita- tions omitted; internal quotation marks omitted.) Ward v. Ramsey, 146 Conn. App. 485 , 490–92, 77

2020The existence of the proximate cause of an injury is determined by looking from the injury to the negligent act complained of for the necessary causal connection. . . . ‘‘In other words, [p]roximate cause [is] defined as an actual cause that is a substantial factor in the resulting harm . . . . [T]he inquiry fundamental to all proximate cause questions . . . [is] whether the harm which occurred was of the same general nature as the foresee- able risk created by the defendant’s negligence.’’ (Cita- tions omitted; internal quotation marks omitted.) Ward v. Ramsey, 146 Conn. App. 485 , 490–92, 77

12020–2020
Kowal v. Hofher green
conn · 1980
2 sentences

2017This substantial factor test reflects the inquiry fundamental to all proximate cause questions, namely, whether the harm [that] occurred was of the same general nature as the foreseeable risk created by the defendant's negligence." (Citations omitted; emphasis added; internal quotation marks omitted.) Id."Legal cause is a hybrid construct, the result of balancing philosophic, pragmatic and moral approaches to causation." Kowal v. Hofher , 181 Conn. 355 , 359, 436 A.2d 1 (1980). "[P]olicy considerations generally underlie the doctrine of proximate cause." Id., at 360 , 436 A.2d 1 .

2017This substantial factor test reflects the inquiry fundamental to all proximate cause questions, namely, whether the harm [that] occurred was of the same general nature as the foreseeable risk created by the defendant's negligence." (Citations omitted; emphasis added; internal quotation marks omitted.) Id."Legal cause is a hybrid construct, the result of balancing philosophic, pragmatic and moral approaches to causation." Kowal v. Hofher , 181 Conn. 355 , 359, 436 A.2d 1 (1980). "[P]olicy considerations generally underlie the doctrine of proximate cause." Id., at 360 , 436 A.2d 1 .

12017–2017
Sansone v. Nationwide Mutual Fire Insurance neutral
connappct · 2001
2 sentences

2013Co., 47 Conn. Supp. 35, 39-41 , 770 A.2d 500 (1999), aff'd, 62 Conn. App. 526, 527 , 771 A.2d 243 (2001) (concluding trial court analysis was “consistent with our applicable law and precedents” and adopting court’s “well reasoned decision”).

2013Co., 47 Conn. Supp. 35, 39-41 , 770 A.2d 500 (1999), aff'd, 62 Conn. App. 526, 527 , 771 A.2d 243 (2001) (concluding trial court analysis was “consistent with our applicable law and precedents” and adopting court’s “well reasoned decision”).

12013–2013
Phelps v. Lankes neutral
connappct · 2003
2 sentences

2013The existence of the proximate cause of an injury is determined by looking from the injury to the negligent act complained of for the necessary causal connection.” (Internal quotation marks omitted.) Phelps v. Lankes, 74 Conn. App. 597, 601-602 , 813 A.2d 100 (2003).

2013The existence of the proximate cause of an injury is determined by looking from the injury to the negligent act complained of for the necessary causal connection.” (Internal quotation marks omitted.) Phelps v. Lankes, 74 Conn. App. 597, 601-602 , 813 A.2d 100 (2003).

12013–2013
Sansone v. Nationwide Mutual Fire Ins., No. Cv98-0411373 (Sep. 24, 1999) green
connsuperct · 1999
2 sentences

2013Co., 47 Conn. Supp. 35, 39-41 , 770 A.2d 500 (1999), aff'd, 62 Conn. App. 526, 527 , 771 A.2d 243 (2001) (concluding trial court analysis was “consistent with our applicable law and precedents” and adopting court’s “well reasoned decision”).

2013Co., 47 Conn. Supp. 35, 39-41 , 770 A.2d 500 (1999), aff'd, 62 Conn. App. 526, 527 , 771 A.2d 243 (2001) (concluding trial court analysis was “consistent with our applicable law and precedents” and adopting court’s “well reasoned decision”).

12013–2013
Archambault v. Soneco/Northeastern, Inc. green
conn · 2008
2 sentences

2012We [decided] that [a separate] instruction on superseding cause complicates what is essentially a proximate cause analysis and risks jur[or] confusion." (Internal quotation marks omitted.) Archambault v. Soneco/Northeastern, Inc., 287 Conn. 20, 43 , 946 A.2d 839 (2008).

2012We [decided] that [a separate] instruction on superseding cause complicates what is essentially a proximate cause analysis and risks jur[or] confusion." (Internal quotation marks omitted.) Archambault v. Soneco/Northeastern, Inc., 287 Conn. 20, 43 , 946 A.2d 839 (2008).

12012–2012
Himmelstein v. Town of Windsor green
connappct · 2009
1 sentence

2012Id. at 49, 974 A.2d 820 .

12012–2012
Birnie v. Electric Boat Corp. green
conn · 2008
2 sentences

2012II We next address the plaintiff's contention that the Appellate Court's proximate cause analysis was inconsistent with our statement in Birnie v. Electric Boat Corp., *845 supra, 288 Conn. 392 , 953 A.2d 28 , that the substantial factor causation standard is met if "the employment, or the risks incidental thereto, contribute[d] to the development of the injury in more than a de minimis way." Id., at 412-13, 953 A.2d 28 .

2012II We next address the plaintiff's contention that the Appellate Court's proximate cause analysis was inconsistent with our statement in Birnie v. Electric Boat Corp., *845 supra, 288 Conn. 392 , 953 A.2d 28 , that the substantial factor causation standard is met if "the employment, or the risks incidental thereto, contribute[d] to the development of the injury in more than a de minimis way." Id., at 412-13, 953 A.2d 28 .

12012–2012
Hummel v. Marten Transport, Ltd. green
connappct · 2009
2 sentences

2011See Labadie v. Norwalk Rehabilitation Services, Inc., 274 Conn. 219, 237-38 , 875 A.2d485 (2005); Voronuk v. Electric Boat Corp., 118 Conn. App. 248, 253 , 982 A.2d 650 (2009); Hummel v. Marten Transport, Ltd., 114 Conn. App. 822, 844 , 970 A.2d 834 , cert. denied, 293 Conn. 907 , 978 A.2d 1109 (2009). 11 We note again that, although the parties entered into an agreement in June, 2006, the plaintiff failed to accept the agreements offered by the employer regarding the maximum medical improvement and 10 percent permanent partial disability rating of the plaintiffs brain. 12 Although both the co

2011See Labadie v. Norwalk Rehabilitation Services, Inc., 274 Conn. 219, 237-38 , 875 A.2d485 (2005); Voronuk v. Electric Boat Corp., 118 Conn. App. 248, 253 , 982 A.2d 650 (2009); Hummel v. Marten Transport, Ltd., 114 Conn. App. 822, 844 , 970 A.2d 834 , cert. denied, 293 Conn. 907 , 978 A.2d 1109 (2009). 11 We note again that, although the parties entered into an agreement in June, 2006, the plaintiff failed to accept the agreements offered by the employer regarding the maximum medical improvement and 10 percent permanent partial disability rating of the plaintiffs brain. 12 Although both the co

12011–2011
Jones v. Commissioner of Correction green
conn · 2009
12011–2011
State v. Luther green
conn · 2009
1 sentence

2011See Labadie v. Norwalk Rehabilitation Services, Inc., 274 Conn. 219, 237-38 , 875 A.2d485 (2005); Voronuk v. Electric Boat Corp., 118 Conn. App. 248, 253 , 982 A.2d 650 (2009); Hummel v. Marten Transport, Ltd., 114 Conn. App. 822, 844 , 970 A.2d 834 , cert. denied, 293 Conn. 907 , 978 A.2d 1109 (2009). 11 We note again that, although the parties entered into an agreement in June, 2006, the plaintiff failed to accept the agreements offered by the employer regarding the maximum medical improvement and 10 percent permanent partial disability rating of the plaintiffs brain. 12 Although both the co

12011–2011
Voronuk v. Electric Boat Corp. green
connappct · 2009
2 sentences

2011See Labadie v. Norwalk Rehabilitation Services, Inc., 274 Conn. 219, 237-38 , 875 A.2d485 (2005); Voronuk v. Electric Boat Corp., 118 Conn. App. 248, 253 , 982 A.2d 650 (2009); Hummel v. Marten Transport, Ltd., 114 Conn. App. 822, 844 , 970 A.2d 834 , cert. denied, 293 Conn. 907 , 978 A.2d 1109 (2009). 11 We note again that, although the parties entered into an agreement in June, 2006, the plaintiff failed to accept the agreements offered by the employer regarding the maximum medical improvement and 10 percent permanent partial disability rating of the plaintiffs brain. 12 Although both the co

2011See Labadie v. Norwalk Rehabilitation Services, Inc., 274 Conn. 219, 237-38 , 875 A.2d485 (2005); Voronuk v. Electric Boat Corp., 118 Conn. App. 248, 253 , 982 A.2d 650 (2009); Hummel v. Marten Transport, Ltd., 114 Conn. App. 822, 844 , 970 A.2d 834 , cert. denied, 293 Conn. 907 , 978 A.2d 1109 (2009). 11 We note again that, although the parties entered into an agreement in June, 2006, the plaintiff failed to accept the agreements offered by the employer regarding the maximum medical improvement and 10 percent permanent partial disability rating of the plaintiffs brain. 12 Although both the co

12011–2011
Lerner v. Fleet Bank green
ca2 · 2006
12011–2011
Agriesto v. Town of Fairfield green
conn · 1943
12009–2009
Ormsby v. Frankel green
conn · 2001
12009–2009
Sullivan v. Metro-North Commuter Railroad green
connappct · 2006
12009–2009
Roy v. Michaud green
conn · 1986
12006–2006
Right v. Breen green
conn · 2006
12006–2006
State v. Ives green
conn · 1995
12006–2006
Moxon v. Board of Trustees of Regional Community Colleges neutral
conn · 1995
12006–2006
Roy v. Michaud green
connappct · 1985
12006–2006
Sirot v. Burns green
connappct · 1995
12006–2006
Right v. Breen green
connappct · 2005
12006–2006
Right v. Breen neutral
connappct · 2005
12006–2006
Bowers v. Bowers green
conn · 2001
12003–2003
Trimel v. Lawrence & Memorial Hospital Rehabilitation Center green
conn · 2001
12003–2003
Trimel v. Lawrence & Memorial Hospital Rehabilitation Center green
connappct · 2001
12003–2003
Vona v. Lerner green
connappct · 2002
12003–2003
Vona v. Lerner green
conn · 2003
12003–2003
Lewis v. Commissioner green
conn · 2003
12003–2003
Grayson v. Wofsey, Rosen, Kweskin & Kuriansky green
conn · 1994
12002–2002
Craig v. Driscoll green
conn · 2001
12002–2002
Cheverie v. Ashcraft & Gerel green
conn · 2001
12002–2002

Statutes the citing opinions construe

CT § Conn. Gen. Stat. § 13a-149 (11) CT § Conn. Gen. Stat. § 52-572h (9) CT § Conn. Gen. Stat. § 13a-144 (8) CT § Conn. Gen. Stat. § 51-199 (7) CT § Conn. Gen. Stat. § 52-557n (4) CT § Conn. Gen. Stat. § 31-275 (3) CT § Conn. Gen. Stat. § 4-1 (3) CT § Conn. Gen. Stat. § 42-110a (3) CT § Conn. Gen. Stat. § 52-572o (3) CT § Conn. Gen. Stat. § 7-2 (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

IL 168 (1911–2026) TX 85 (1932–2025) CA 73 (1927–2025) CT 48 (1967–2020) NY 40 (1911–2026) GA 37 (1954–2025) MD 35 (1943–2025) WA 34 (1959–2025) IA 32 (1955–2026) MI 27 (1895–2026) NJ 24 (1961–2026) OH 23 (1988–2025) TN 22 (1897–2025) UT 19 (1993–2026) KS 17 (1917–2025) IN 17 (1939–2017) NC 17 (1928–2025) CO 15 (1951–2025) NM 13 (1985–2019) PA 13 (1934–2021) AZ 12 (1982–2022) DC 10 (1987–2020) VT 9 (2003–2023) MO 9 (1996–2019) FL 9 (1981–2016) ID 9 (1978–2018) DE 8 (1936–2023) LA 8 (1940–2012) MN 7 (1937–2025) MT 7 (1985–2008) MS 6 (1988–2005) WV 6 (1983–2021) VA 6 (1936–2022) NV 6 (1985–2022) OK 5 (1985–2024) SD 4 (1948–2011) WI 4 (1903–2024) WY 4 (1989–2023) AL 4 (1974–2009) NE 3 (2005–2023) HI 3 (1975–2014) ME 3 (1934–2020) MA 3 (2000–2002) AK 3 (1981–2024) OR 3 (1914–2013) ND 3 (1994–2009) RI 2 (1994–1994) VI 2 (2012–2013) NH 2 (1923–2001) AR 2 (1971–2018)

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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