Lighthouse Landings, Inc. v. Connecticut Light & Power Co.
300 Conn. 325
| Conn. | 2011Background
- Commercial lease terminated by power company after Lighthouse failed to obtain permits within 180 days and after a 60-day extension; Lighthouse sued alleging improper termination and related damages and misrepresentation theories.
- Power company filed declaratory judgment action seeking a judicial determination that termination was proper and that lease was of no further force; actions were consolidated and stayed.
- Lighthouse sought prejudgment remedy in the civil action and later amended its complaint; the trial court reinstated the lease on equitable nonforfeiture grounds but this was reversed on appeal in Lighthouse Landings.
- On remand, the trial court considered Lighthouse’s damages claims in light of Lighthouse Landings; it granted summary judgment to power company on breach-of-lease, good faith, and promissory estoppel but denied on misrepresentation and CUTPA claims.
- This appeal concerns whether Lighthouse’s remaining misrepresentation and CUTPA claims are barred by collateral estoppel or res judicata, given the prior Lighthouse Landings decision and the declaratory judgment action.
- The Supreme Court ultimately held that remand was properly construed, collateral estoppel did not preclude the misrepresentation and CUTPA claims, but res judicata barred those claims because they were fully litigated in the declaratory judgment action.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Collaterally estopped by Lighthouse Landings? | Lighthouse argues Lighthouse Landings did not decide post-extension conduct; misrepresentation/CUTPA not barred. | Power Co. argues Lighthouse Landings precludes surviving claims. | Collateral estoppel does not bar misrepresentation/CUTPA claims. |
| Res judicata barring misrepresentation/CUTPA claims? | These claims arose from post-extension conduct and were not decided in declaratory judgment. | Declaratory judgment action resolved termination, triggering res judicata. | Res judicata bars misrepresentation/CUTPA claims. |
| Did declaratory judgment preclude further litigation in the civil action? | Restatement §33 allows relief beyond declaratory relief; claims should survive. | Declaratory judgment limited to matters declared and issues actually litigated. | Yes, res judicata bars future claims; declaratory judgment has preclusive effect under §33. |
| Did the trial court properly follow the remand mandate regarding damages analysis? | Court correctly considered preclusive effect of Lighthouse Landings on damages. | Court erred by not fully applying collateral estoppel to all damages claims. | Court complied with remand directive; damages claims resolved by res judicata. |
Key Cases Cited
- Connecticut Light & Power Co. v. Lighthouse Landings, Inc., 279 Conn. 90 (2006) (remand directive; damages in light of Lighthouse Landings; collateral estoppel not preclusive for post-extension conduct)
- Duhaime v. American Reserve Life Ins. Co., 200 Conn. 360 (1986) (restatement transactional test for res judicata; merger/claim preclusion)
- Weiss v. Weiss, 297 Conn. 446 (2010) (flexibility of res judicata; harsh results; balance interests)
- Duane Reade, Inc. v. St. Paul Fire & Marine Ins. Co., 600 F.3d 190 (2d Cir. 2010) (declaratory judgment exception to res judicata; preclusion limited to issues actually decided)
- Harborside Refrigerated Services, Inc. v. Vogel, 959 F.2d 368 (2d Cir. 1992) (purpose of declaratory judgment and res judicata interplay)