234 Conn.App. 609
Conn. App. Ct.2025Background
- Connor Dushay, a minor and hockey player, was injured during an unsupervised practice at Wonderland ice rink—he was bullied and suffered broken bones.
- The defendant, Southern Connecticut Hockey League, LLC, operated a youth hockey league that organized and scheduled games, not practices, at rented local rinks including Wonderland.
- The league’s materials stated the registration fee covered only games and playoffs, not practices; local rinks could offer "open ice" for unofficial team use when not otherwise rented.
- The plaintiff alleged that the league was negligent in not supervising the practice and argued Wonderland acted as the league's agent.
- The trial court granted summary judgment for the league, finding no duty of care owed as practices were not part of the league’s activities and no agency relationship existed with Wonderland for practices.
- The appellate court reviewed the ruling following standard summary judgment and agency law principles.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did the league owe a duty of care to supervise practices? | Dushay argued the league’s season included practices, making supervision its duty. | League argued practices weren’t part of the official season; no evidence they controlled practices. | No duty of care; no evidence practices were included or foreseeable to defendant. |
| Were team practices part of the league’s official season? | Plaintiff referenced belief, emails, and flyer suggesting inclusion. | Defendant showed flyer only referenced games; contract with rink was for games, not practices. | Practices not included; only games covered. |
| Was Wonderland acting as the league's agent during practice? | Plaintiff claimed the rink acted as an agent for the league regarding team activities, including practice. | League argued no evidence of agency; practices arranged solely by rink/volunteers, not league direction. | No agency relationship for practices shown, only for games. |
| Should the summary judgment decision be reversed? | Plaintiff asserted factual disputes should go to jury, especially regarding foreseeability and agency. | Defendant claimed all facts relevant to duty and agency were undisputed and summary judgment was proper. | Summary judgment affirmed; no genuine issues of material fact. |
Key Cases Cited
- Jarmie v. Troncale, 306 Conn. 578 (Conn. 2012) (court sets standard for duty of care analysis in negligence cases)
- Cefaratti v. Aranow, 321 Conn. 593 (Conn. 2016) (clarifies tests for actual and apparent agency in tort)
- Hallas v. Boehmke & Dobosz, Inc., 239 Conn. 658 (Conn. 1997) (agency relationships require a manifestation of principal’s authority to agent)
- Eldridge v. Hospital of Central Connecticut, 230 Conn. App. 666 (Conn. App. Ct. 2025) (summary judgment standard)
- Roux v. Coffey, 230 Conn. App. 130 (Conn. App. Ct. 2025) (elements of negligence and duty as a legal question)