Artie's Auto Body, Inc. v. Hartford Fire Ins. Co., 317 Conn. 602

Artie’s Auto Body and related shops filed a class action against Hartford alleging CUTPA violations based on DRP labor-rate practices.
Evidence showed Hartford appraisers used DRP rates (about $41–$46/hour) in negotiations, which were lower than shops’ posted rates ($65–$78/hour).
Most auto body repairs are insurance purchases; shops typically cannot obtain posted rates in practice but claim posted rates reflect true value.
Trial evidence included communications from Hartford’s appraisers questioning the fairness of prevailing rates and department guidance endorsing negotiating rather than fixing rates.
The trial court instructed the jury under the cigarette rule and the court later denied motions to set aside the verdict; the trial court issued a permanent injunction against interference with appraiser independence.
On Hartford’s appeal, the court reversed, holding that § 38a-790-8 does not support the plaintiffs’ CUTPA claim and that CUIPA does not authorize private CUTPA liability for this conduct.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether CUTPA liability for insurance-related practice requires CUIPA violation	Acordia allows CUTPA despite no CUIPA violation	CUIPA governs insurance practices; absence of violation defeats CUTPA	CUTPA claim fails; no CUIPA violation supports it.
Whether § 38a-790-8 can ground CUTPA liability for labor-rate practices	Regulation embodies public policy against biased appraisals	Regulation regulates appraisers, not labor-rate negotiations	§ 38a-790-8 does not support CUTPA liability here.
Whether the department letters to the AG are material discovery or public policy issues	Letters reflect official interpretation favoring plaintiffs	Letters were discoverable and misused; new trial warranted	No reversible error; letters did not change outcome.
Whether the trial court’s cigarette-rule instruction was correct given federal law changes	Cigarette-rule remains controlling under CUTPA	Substantial unjustified injury standard applies	Remain governed by cigarette rule; court did not adopt federal standard.

Mead v. Burns, 199 Conn. 651 (1986) (CUIPA actions may be brought under CUTPA; consistency with underlying statutes required)
State v. Acordia, Inc., 310 Conn. 1 (2013) (CUIPA is the exclusive public policy source for insurance practices; general CUTPA relief unlikely)
Nazami v. Patrons Mutual Ins. Co., 280 Conn. 619 (2006) (CUIPA requires CUIPA violation for CUTPA claim)
Mead v. Burns, 199 Conn. 651 (1986) (as above)
Ulbrich v. Groth, 310 Conn. 375 (2013) (addresses cigarette rule preservation and federal law alignment)
Glazer v. Dress Barn, Inc., 274 Conn. 33 (2005) (CUTPA use guided by federal law interpretations; cigarette rule analysis)