fixture analysis (Connecticut) · Go Syfert
← Connecticut issues

fixture analysis in Connecticut

5 Connecticut opinions name it 2 courts 1976–2022 2 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 (4)

CaseFollowedCited
Capen v. Peckhamgreen
conn · 1868 · cited in 2 Connecticut opinions naming this issue, 1976–2022
2 sentences

2022A fixture is ‘‘a piece of personal property [that] has become so connected to realty . . . as to have lost its character as personalty . . . .’’ ATC Partnership v. Windham, 268 Conn. 463, 480 , 845 A.2d 389 (2004); see Capen v. Peckham, 35 Conn. 88, 93 (1868) (‘‘Property is divided into two great divisions, things personal and things real, and fixtures may be found along the dividing line.

1976The plaintiff claims that the trial court erred as a matter of law in concluding that the bowling equipment was not covered under the fixture clause of the 1964 mortgage but was instead personalty, title to which remained in Mauro. “[I]t is essential to constitute a fixture that an article should not only be annexed to the freehold, but that it should clearly appear from an inspection of the property itself, taking into consideration the character of the annexation, the nature and the adaptation of the article annexed to the uses and purposes to which that part of the building was appropriated

12
Pfeifle v. Tanabegreen
nd · 2000 · cited in 1 Connecticut opinions naming this issue, 2022–2022
1 sentence

2022Vallerie v. Stonington, 253 Conn. 371 , 372–73, 751 A.2d 829 (2000); Waterbury Petroleum Products, Inc. v. Canaan Oil & Fuel Co., [ 193 Conn. 208, 217 , 477 A.2d 988 (1984)]; see also Pfeifle v. Tanabe, 620 N.W.2d 167, 174 (N.D. 2000) (whether parties intended to treat existing fixtures as personalty and thereby constructively severed property from realty is question of fact).

11
Historic District Commission v. Hallgreen
conn · 2007 · cited in 1 Connecticut opinions naming this issue, 2022–2022
2 sentences

2022In contrast, § 12-64 (a) contains no such limiting language, and, thus, the Hawaii case does not support the plaintiff’s claim. 23 As the trial court stated, ‘‘[n]either party disputes that the plaintiff is a company engaged in the production of electrical energy.’’ 24 This court has also declined to apply a fixture analysis in the context of § 7-147a (a), which defines a ‘‘structure’’ as ‘‘any combination of materials, other than a building, which is affixed to the land, and shall include, but not be limited to, signs, fences and walls . . . .’’ (Emphasis added; internal quotation marks omitt

2022In contrast, § 12-64 (a) contains no such limiting language, and, thus, the Hawaii case does not support the plaintiff’s claim. 23 As the trial court stated, ‘‘[n]either party disputes that the plaintiff is a company engaged in the production of electrical energy.’’ 24 This court has also declined to apply a fixture analysis in the context of § 7-147a (a), which defines a ‘‘structure’’ as ‘‘any combination of materials, other than a building, which is affixed to the land, and shall include, but not be limited to, signs, fences and walls . . . .’’ (Emphasis added; internal quotation marks omitt

11
Wronowski v. Redevelopment Agencygreen
conn · 1980 · cited in 1 Connecticut opinions naming this issue, 2004–2004
2 sentences

2004See Wronowski v. Redevelopment Agency, 180 Conn. 579, 584-85 , 430 A.2d 1284 (1980); Stanley Works v. New Britain Redevelopment Agency, 155 Conn. 86, 100-102 , 230 A.2d 9 (1967); Harvey Textile Co. v. Hill, 135 Conn. 686, 689-90 , 67 A.2d 851 (1949).

2004See Wronowski v. Redevelopment Agency, 180 Conn. 579, 584-85 , 430 A.2d 1284 (1980); Stanley Works v. New Britain Redevelopment Agency, 155 Conn. 86, 100-102 , 230 A.2d 9 (1967); Harvey Textile Co. v. Hill, 135 Conn. 686, 689-90 , 67 A.2d 851 (1949).

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 (7)

CaseCitedYears
Waterbury Petroleum Products, Inc. v. Canaan Oil & Fuel Co. green
conn · 1984
2 sentences

2022Vallerie v. Stonington, 253 Conn. 371 , 372–73, 751 A.2d 829 (2000); Waterbury Petroleum Products, Inc. v. Canaan Oil & Fuel Co., [ 193 Conn. 208, 217 , 477 A.2d 988 (1984)]; see also Pfeifle v. Tanabe, 620 N.W.2d 167, 174 (N.D. 2000) (whether parties intended to treat existing fixtures as personalty and thereby constructively severed property from realty is question of fact).

2022Vallerie v. Stonington, 253 Conn. 371 , 372–73, 751 A.2d 829 (2000); Waterbury Petroleum Products, Inc. v. Canaan Oil & Fuel Co., [ 193 Conn. 208, 217 , 477 A.2d 988 (1984)]; see also Pfeifle v. Tanabe, 620 N.W.2d 167, 174 (N.D. 2000) (whether parties intended to treat existing fixtures as personalty and thereby constructively severed property from realty is question of fact).

12022–2022
Vallerie v. Town of Stonington green
conn · 2000
2 sentences

2022Vallerie v. Stonington, 253 Conn. 371 , 372–73, 751 A.2d 829 (2000); Waterbury Petroleum Products, Inc. v. Canaan Oil & Fuel Co., [ 193 Conn. 208, 217 , 477 A.2d 988 (1984)]; see also Pfeifle v. Tanabe, 620 N.W.2d 167, 174 (N.D. 2000) (whether parties intended to treat existing fixtures as personalty and thereby constructively severed property from realty is question of fact).

2022Vallerie v. Stonington, 253 Conn. 371 , 372–73, 751 A.2d 829 (2000); Waterbury Petroleum Products, Inc. v. Canaan Oil & Fuel Co., [ 193 Conn. 208, 217 , 477 A.2d 988 (1984)]; see also Pfeifle v. Tanabe, 620 N.W.2d 167, 174 (N.D. 2000) (whether parties intended to treat existing fixtures as personalty and thereby constructively severed property from realty is question of fact).

12022–2022
ATC Partnership v. Town of Windham green
conn · 2004
2 sentences

2022A fixture is ‘‘a piece of personal property [that] has become so connected to realty . . . as to have lost its character as personalty . . . .’’ ATC Partnership v. Windham, 268 Conn. 463, 480 , 845 A.2d 389 (2004); see Capen v. Peckham, 35 Conn. 88, 93 (1868) (‘‘Property is divided into two great divisions, things personal and things real, and fixtures may be found along the dividing line.

2022A fixture is ‘‘a piece of personal property [that] has become so connected to realty . . . as to have lost its character as personalty . . . .’’ ATC Partnership v. Windham, 268 Conn. 463, 480 , 845 A.2d 389 (2004); see Capen v. Peckham, 35 Conn. 88, 93 (1868) (‘‘Property is divided into two great divisions, things personal and things real, and fixtures may be found along the dividing line.

12022–2022
City of New London v. Foss & Bourke, Inc. neutral
connappct · 2004
2 sentences

2005The Appellate Court affirmed the judgment of the trial court; New London v. Foss & Bourke, Inc., 85 Conn. App. 275, 284 , 857 A.2d 370 (2004); and upheld the rejection of the doctrine on the ground that “[n]o Connecticut court ha[d] adopted the assembled economic unit doctrine,” and that “[a]ll of the Connecticut cases that the defendant relie [d] on consistently applied] the principle that just compensation in an eminent domain action [was] based on the market value of the condemned property and in accordance with the traditional fixture analysis.” Id., 280 .

2005The Appellate Court affirmed the judgment of the trial court; New London v. Foss & Bourke, Inc., 85 Conn. App. 275, 284 , 857 A.2d 370 (2004); and upheld the rejection of the doctrine on the ground that “[n]o Connecticut court ha[d] adopted the assembled economic unit doctrine,” and that “[a]ll of the Connecticut cases that the defendant relie [d] on consistently applied] the principle that just compensation in an eminent domain action [was] based on the market value of the condemned property and in accordance with the traditional fixture analysis.” Id., 280 .

12005–2005
Stanley Works v. New Britain Redevelopment Agency green
conn · 1967
2 sentences

2004See Wronowski v. Redevelopment Agency, 180 Conn. 579, 584-85 , 430 A.2d 1284 (1980); Stanley Works v. New Britain Redevelopment Agency, 155 Conn. 86, 100-102 , 230 A.2d 9 (1967); Harvey Textile Co. v. Hill, 135 Conn. 686, 689-90 , 67 A.2d 851 (1949).

2004See Wronowski v. Redevelopment Agency, 180 Conn. 579, 584-85 , 430 A.2d 1284 (1980); Stanley Works v. New Britain Redevelopment Agency, 155 Conn. 86, 100-102 , 230 A.2d 9 (1967); Harvey Textile Co. v. Hill, 135 Conn. 686, 689-90 , 67 A.2d 851 (1949).

12004–2004
Harvey Textile Co. v. Hill green
conn · 1949
2 sentences

2004See Wronowski v. Redevelopment Agency, 180 Conn. 579, 584-85 , 430 A.2d 1284 (1980); Stanley Works v. New Britain Redevelopment Agency, 155 Conn. 86, 100-102 , 230 A.2d 9 (1967); Harvey Textile Co. v. Hill, 135 Conn. 686, 689-90 , 67 A.2d 851 (1949).

2004See Wronowski v. Redevelopment Agency, 180 Conn. 579, 584-85 , 430 A.2d 1284 (1980); Stanley Works v. New Britain Redevelopment Agency, 155 Conn. 86, 100-102 , 230 A.2d 9 (1967); Harvey Textile Co. v. Hill, 135 Conn. 686, 689-90 , 67 A.2d 851 (1949).

12004–2004
Stone v. Rosenfield green
conn · 1954
2 sentences

1976The plaintiff claims that the trial court erred as a matter of law in concluding that the bowling equipment was not covered under the fixture clause of the 1964 mortgage but was instead personalty, title to which remained in Mauro. “[I]t is essential to constitute a fixture that an article should not only be annexed to the freehold, but that it should clearly appear from an inspection of the property itself, taking into consideration the character of the annexation, the nature and the adaptation of the article annexed to the uses and purposes to which that part of the building was appropriated

1976The plaintiff claims that the trial court erred as a matter of law in concluding that the bowling equipment was not covered under the fixture clause of the 1964 mortgage but was instead personalty, title to which remained in Mauro. “[I]t is essential to constitute a fixture that an article should not only be annexed to the freehold, but that it should clearly appear from an inspection of the property itself, taking into consideration the character of the annexation, the nature and the adaptation of the article annexed to the uses and purposes to which that part of the building was appropriated

11976–1976

Where else courts name it

CT 5 (1976–2022) MI 5 (1997–2024) ME 4 (1992–2025) KS 2 (2015–2022) NY 2 (1936–2009) MD 2 (1992–2004) VA 2 (2017–2017) HI 2 (2014–2020) NH 2 (1996–2017)

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.

← Caselaw search · G Cite Topics · Brief Check