New London County Mutual Insurance Co. v. Nantes, 303 Conn. 737

Two California medical residents suffered serious carbon monoxide injuries after Nantes left her running car in an attached garage and the house filled with CO.
Plaintiff NL Mutual insured Nantes under a homeowner’s policy that excludes bodily injury arising out of the ownership, maintenance, use, loading or unloading of motor vehicles.
Dzhgalian and Melikyan assigned rights under Nantes’ policy to recover damages; they and Nantes pursued related claims in California arbitration and anticipated further action in Connecticut.
NL Mutual filed a declaratory judgment in Connecticut seeking a ruling that Nantes’ policy does not provide coverage for the injuries.
The trial court granted summary judgment in NL Mutual’s favor, concluding the injuries fell within the motor vehicle exclusion.
On appeal, the issues include personal jurisdiction over the nonresident claimants, proper use of declaratory judgment, and the scope of the policy exclusion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether CT court had personal jurisdiction over Dzhgalian and Melikyan	Dzhgalian and Melikyan transacted CT business via lodging/transport arrangement with Nantes.	No CT transaction or connection sufficient for jurisdiction.	Yes; CT court properly exercised jurisdiction.
Whether the complaint was a proper declaratory judgment action	DJ action seeks adjudication of rights under the policy; bona fide dispute exists.	Action improperly seeks advisory relief or forum manipulation.	Proper declaratory judgment action; not an advisory/as a misuse.
Whether the motor vehicle exclusion applies to the injuries	Injuries arose out of Nantes' use of the car (parking/left running) and are excluded.	Injuries did not arise out of use of a motor vehicle; doctrine of concurrent causation may apply.	Exclusion applies; injuries arose out of the use of a motor vehicle.
Whether concurrent causes extend coverage	Not necessary; Hogle framework controls; exclusion remains dispositive.	Concurrent causes could bring covered events within policy coverage.	Not controlling here; Hogle controls; coverage not extended.
Whether dragging injuries were within the exclusion	Dragging injuries were caused by the initial use of the car and are within the exclusion.	Dragging injuries might be seen as separate from car use.	Dragging injuries arose out of the car use; within exclusion.

Hogle v. Hogle, 167 Conn. 572 (Conn. 1975) (defines broad 'arising out of the use' standard for auto exclusions)
Board of Education v. St. Paul Fire & Marine Ins. Co., 261 Conn. 37 (Conn. 2002) (supports expansive causation interpretation under 'use' language)
Aetna Life & Casualty Co. v. Bulaong, 218 Conn. 51 (Conn. 1991) (defines broad meaning of 'use' of an automobile)
Heyman Associates No. 1 v. Ins. Co. of Penn., 231 Conn. 756 (Conn. 1995) (insurance exclusions read narrowly only if ambiguity; here not ambiguous)
Liberty Mutual Ins. Co. v. Lone Star Industries, Inc., 290 Conn. 767 (Conn. 2009) (declaratory judgments used to resolve insurance rights)