resulting violation (Connecticut) · Go Syfert
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resulting violation in Connecticut

44 Connecticut opinions name it 3 courts 1985–2012 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 (5)

CaseFollowedCited
Dupuis v. Submarine Base Credit Union, Inc.green
conn · 1976 · cited in 11 Connecticut opinions naming this issue, 1993–2007
2 sentences

2007As noted, this exception applies where the party claiming estoppel would be subjected to substantial loss if the public agency were permitted to negate the acts of its agents.” (Citations omitted.) Kimberly-Clark Corp. v. Dubno, 204 Conn. *727 137, 148, 527 A.2d 679 (1987); see also Dupuis v. Submarine Base Credit Union, Inc., 170 Conn. 344, 354 , 365 A.2d 1093 (1976) (application of equitable estoppel against government agency is “limited and invoked [1] only with great caution, [2] only when the resulting violation has been unjustifiably induced by an agent having authority in such matters,

2007As noted, this exception applies where the party claiming estoppel would be subjected to substantial loss if the public agency were permitted to negate the acts of its agents.” (Citations omitted.) Kimberly-Clark Corp. v. Dubno, 204 Conn. *727 137, 148, 527 A.2d 679 (1987); see also Dupuis v. Submarine Base Credit Union, Inc., 170 Conn. 344, 354 , 365 A.2d 1093 (1976) (application of equitable estoppel against government agency is “limited and invoked [1] only with great caution, [2] only when the resulting violation has been unjustifiably induced by an agent having authority in such matters,

511
Gelinas v. Town of West Hartfordgreen
conn · 1993 · cited in 9 Connecticut opinions naming this issue, 1994–2002
2 sentences

1999"Estoppel against municipalities is . . . limited and may be invoked against the enforcement of zoning regulations (1) only with great caution, (2) only when the resulting violation has been unjustifiably induced by an agent having authority in such matters, and (3) only when special circumstances make it highly inequitable or oppressive to enforce the regulations, Gelinas v. West Hartford, 225 Conn. 575 , 590 (citation omitted).

1996"The law of equitable estoppel as applied to municipalities in the enforcement of zoning laws is well established. . . . `[I]n special circumstances, a municipality may be estopped from enforcing its zoning regulations.' . . . `[A]lthough estoppel may not generally be invoked against a public agency in the I exercise of its governmental functions . . . an exception is made where the party claiming estoppel would be subjected to a substantial loss if the municipality were permitted to negate the acts of its agents . . . [Accordingly, . . . estoppel] against municipalities is . . . limited and m

59
Town of West Hartford v. Rechelgreen
conn · 1983 · cited in 12 Connecticut opinions naming this issue, 1988–2003
2 sentences

2003In zoning matters, estoppel is available "(1) only with great caution, (2) only when the resulting violation has been unjustifiably induced by an agent having authority in such matters, and (3) only when special circumstances make it highly inequitable or oppressive to enforce the regulations." West Hartford v. Rechel , supra, at p. 121 (citations omitted).

2002"In municipal zoning cases, however, estoppel may be invoked 1) only with great caution, 2) only when the resulting violation has been unjustifiably induced by an agent having authority in such matters and 3) only when special circumstances make it highly inequitable or oppressive to enforce the regulations." West Hartford v. Rechel , 190 Conn. 114 , 121 (1983).

112
Town of West Hartford v. Gelinasgreen
connappct · 1989 · cited in 2 Connecticut opinions naming this issue, 1990–1993
2 sentences

1993Dupuis v. Submarine Base Credit Union, Inc., [ 170 Conn. 344, 354 , 365 A.2d 1093 (1976)].” Zoning Commission v. Lescynski, 188 Conn. 724, 731-32 , 453 A.2d 1144 (1982); see also West Hartford v. Gelinas, 18 Conn. App. 688, 691 , 559 A.2d 1176 (1989).

1990The cases of West Hartford v. Rechel, supra, 121 and Zoning Commission v. Lescynski, 188 Conn. 724 , 732 , state that estoppel may be applied to municipal zoning cases "(1) only with great caution, (2) only when the resulting violation has been unjustifiably induced by an agent having authority in such matters and (3) only when special circumstances make it highly inequitable or oppressive to enforce the regulations." See also Dupuis v. Submarine Base Credit Union, Inc., supra, 354; West Hartford v. Gelinas, 18 Conn. App. 688 , 691 .

12
Correa v. Wardgreen
connappct · 2005 · cited in 1 Connecticut opinions naming this issue, 2012–2012
2 sentences

2012See also Correa v. Ward, 91 Conn.App. 142, 147 , 881 A.2d 393 (2005) (construing analogous language in General Statutes §§ 47a-20 and 47a-20a of Landlord and Tenant Act).

2012See also Correa v. Ward, 91 Conn.App. 142, 147 , 881 A.2d 393 (2005) (construing analogous language in General Statutes §§ 47a-20 and 47a-20a of Landlord and Tenant Act).

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 (9)

CaseCitedYears
Zoning Commission v. Lescynski green
conn · 1982
2 sentences

2003An exception is made where the party claiming estoppel would be subjected to a substantial loss if the municipality were permitted to negate the acts of its agents; however, the exception is to be applied "(1) only with great caution, (2) only when the resulting violation has been unjustifiably induced by an agent having authority in such matters, and (3) only when special circumstances make it highly inequitable or oppressive to enforce the regulations." Zoning Commission v. Lescynski, 188 Conn. 724 , 732 (1982).

2002An exception is made where the party claiming estoppel would be subjected to a substantial loss if the municipality were permitted to negate the acts of its agents; however, the exception is to be applied "(1) only with great caution, (2) only CT Page 16656 when the resulting violation has been unjustifiably induced by an agent having authority in such matters, and (3) only when special circumstances make it highly inequitable or oppressive to enforce the regulations." Zoning Commission v. Lescynski , 188 Conn. 724 , 732 (1982).

131985–2003
Dornfried v. October Twenty-Four, Inc. green
conn · 1994
2 sentences

1998"The courts have consistently held that the general rule applicable to the invocation of the doctrine of estoppel against municipal corporations should be limited and invoked (1) only with great caution, (2) only when the resulting violation has been unjustifiably induced by an agent having authority in such matters, and (3) only when special circumstances make it highly inequitable or oppressive to enforce the zoning or building regulations." (Emphasis in original.) Dupuis v. Submarine Base Credit Union, Inc. , 170 Conn. 344 , 354 , 365 A.2d 1093 (1976). "[E]stoppel always requires proof of t

1998"The courts have consistently held that the general rule applicable to the invocation of the doctrine of estoppel against municipal corporations should be limited and invoked (1) only with great caution, (2) only when the resulting violation has been unjustifiably induced by an agent having authority in such matters, and (3) only when special circumstances make it highly inequitable or oppressive to enforce the zoning or building regulations." (Emphasis in original.) Dupuis v. Submarine Base Credit Union, Inc. , 170 Conn. 344 , 354 , 365 A.2d 1093 (1976). "[E]stoppel always requires proof of t

81995–2000
Bauer v. Waste Management of Connecticut, Inc. green
conn · 1995
2 sentences

2003In municipal zoning cases, however, estoppel may be invoked (1) only with great caution, (2) only when the resulting violation has been unjustifiably induced by an agent having authority in such matters, and (3) only when special circumstances make it highly inequitable or oppressive to enforce the regulations.” (Citations omitted; internal quotation marks omitted.) Bauer v. Waste Management of Connecticut, Inc., 234 Conn. 221, 246-47 , 662 A.2d 1179 (1995).

2003In municipal zoning cases, however, estoppel may be invoked (1) only with great caution, (2) only when the resulting violation has been unjustifiably induced by an agent having authority in such matters, and (3) only when special circumstances make it highly inequitable or oppressive to enforce the regulations.” (Citations omitted; internal quotation marks omitted.) Bauer v. Waste Management of Connecticut, Inc., 234 Conn. 221, 246-47 , 662 A.2d 1179 (1995).

41996–2003
State v. Nelson green
connappct · 2001
2 sentences

2009In State v. Nelson, 67 Conn. App. 168 , 786 A.2d 1171 (2001), a case sharing a similar factual predicate with the present appeal, we applied the substantial compliance test set forth in Ocasio , and the resulting analysis is instructive.

2009In State v. Nelson, 67 Conn. App. 168 , 786 A.2d 1171 (2001), a case sharing a similar factual predicate with the present appeal, we applied the substantial compliance test set forth in Ocasio , and the resulting analysis is instructive.

12009–2009
Kimberly-Clark Corp. v. Dubno green
conn · 1987
1 sentence

2007As noted, this exception applies where the party claiming estoppel would be subjected to substantial loss if the public agency were permitted to negate the acts of its agents.” (Citations omitted.) Kimberly-Clark Corp. v. Dubno, 204 Conn. *727 137, 148, 527 A.2d 679 (1987); see also Dupuis v. Submarine Base Credit Union, Inc., 170 Conn. 344, 354 , 365 A.2d 1093 (1976) (application of equitable estoppel against government agency is “limited and invoked [1] only with great caution, [2] only when the resulting violation has been unjustifiably induced by an agent having authority in such matters,

12007–2007
Middlesex Mutual Assurance Co. v. Walsh green
conn · 1991
2 sentences

1994“Estoppel against municipalities is therefore limited and may be invoked against the enforcement of zoning regulations (1) only with great caution, (2) only when the resulting violation has been unjustifiably induced by an agent having authority in such matters, and (3) only when special circumstances make it highly inequitable or oppressive to enforce the regulations.” (Internal quotation marks omitted.) Gelinas v. West Hartford, 225 Conn. 575, 590 , 626 A.2d 259 (1993); Zoning Commission v. Lescynski, supra, 731 . “[A]ny claim of estoppel is predicated on proof of two essential elements: the

1994“Estoppel against municipalities is therefore limited and may be invoked against the enforcement of zoning regulations (1) only with great caution, (2) only when the resulting violation has been unjustifiably induced by an agent having authority in such matters, and (3) only when special circumstances make it highly inequitable or oppressive to enforce the regulations.” (Internal quotation marks omitted.) Gelinas v. West Hartford, 225 Conn. 575, 590 , 626 A.2d 259 (1993); Zoning Commission v. Lescynski, supra, 731 . “[A]ny claim of estoppel is predicated on proof of two essential elements: the

11994–1994
O'Sullivan v. Bergenty green
conn · 1990
2 sentences

1994“Estoppel against municipalities is therefore limited and may be invoked against the enforcement of zoning regulations (1) only with great caution, (2) only when the resulting violation has been unjustifiably induced by an agent having authority in such matters, and (3) only when special circumstances make it highly inequitable or oppressive to enforce the regulations.” (Internal quotation marks omitted.) Gelinas v. West Hartford, 225 Conn. 575, 590 , 626 A.2d 259 (1993); Zoning Commission v. Lescynski, supra, 731 . “[A]ny claim of estoppel is predicated on proof of two essential elements: the

1994“Estoppel against municipalities is therefore limited and may be invoked against the enforcement of zoning regulations (1) only with great caution, (2) only when the resulting violation has been unjustifiably induced by an agent having authority in such matters, and (3) only when special circumstances make it highly inequitable or oppressive to enforce the regulations.” (Internal quotation marks omitted.) Gelinas v. West Hartford, 225 Conn. 575, 590 , 626 A.2d 259 (1993); Zoning Commission v. Lescynski, supra, 731 . “[A]ny claim of estoppel is predicated on proof of two essential elements: the

11994–1994
Bozzi v. Bozzi green
conn · 1979
1 sentence

1992The former, that the party against whom estoppel is claimed, must do or say something calculated or intended to induce another party to believe that certain facts exist and to act on that belief; and the other party must change its position in reliance on those facts, thereby incurring some injury, Bozzi v. Bozzi, 177 Conn. 232 , 242 and the latter; that estoppel against a municipality "may be invoked" (1) only with great caution (2) only when the resulting violation has been unjustifiably induced by an agent having authority in such matters and (3) only when special circumstances make it high

11992–1992
Tomlin v. Personnel Appeal Board green
conn · 1979
1 sentence

1992The former, that the party against whom estoppel is claimed, must do or say something calculated or intended to induce another party to believe that certain facts exist and to act on that belief; and the other party must change its position in reliance on those facts, thereby incurring some injury, Bozzi v. Bozzi, 177 Conn. 232 , 242 and the latter; that estoppel against a municipality "may be invoked" (1) only with great caution (2) only when the resulting violation has been unjustifiably induced by an agent having authority in such matters and (3) only when special circumstances make it high

11992–1992

Statutes the citing opinions construe

CT § Conn. Gen. Stat. § 51-199 (4) CT § Conn. Gen. Stat. § 8-12 (4) CT § Conn. Gen. Stat. § 8-2 (3) CT § Conn. Gen. Stat. § 8-8 (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

IN 429 (1985–2026) CT 44 (1985–2012) CA 36 (1968–2026) IL 27 (1979–2025) TX 25 (1927–2019) NY 20 (1929–2024) PA 14 (1931–2025) DE 13 (1988–2023) FL 12 (1982–2026) OH 11 (1988–2023) TN 10 (1978–2025) MI 10 (1952–2025) WA 10 (1995–2026) GA 10 (1977–2024) MO 8 (1912–2020) WV 8 (1942–2022) LA 7 (1986–2020) MT 7 (1984–2022) OR 7 (1945–2023) MA 6 (1975–2025) NJ 6 (1985–2022) WI 6 (1932–2025) VA 5 (2000–2012) UT 5 (1942–2012) SD 5 (2002–2023) VT 5 (1988–2026) NV 4 (2015–2015) MD 4 (1990–2021) AZ 4 (1996–2020) DC 4 (1976–1994) NM 4 (1982–2002) IA 4 (1995–2009) RI 3 (1994–2015) OK 3 (1961–2001) KY 3 (2024–2026) NC 3 (1951–1999) KS 3 (2005–2025) ME 3 (1985–2020) NE 3 (1994–1998) CO 2 (1995–2019) AR 2 (1974–1975) AL 2 (1979–2014)

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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