Rutter v. Janis, 334 Conn. 722

On May 9, 2013 (about 7:00 p.m.), Danbury Fair Hyundai, LLC (dealer) and Luis Martins executed a temporary loan agreement under Gen. Stat. § 14-60(a) because vehicle registration was pending; the dealer loaned its dealer number plate.
On June 8, 2013 (about 3:00 p.m.), Martins was in a crash while the dealer plate was displayed; passengers were injured and one died.
Plaintiffs sued the dealer claiming the loan exceeded § 14-60(a)’s 30-day limit and thus the dealer was not statutorily insulated from liability.
The trial court granted summary judgment for the dealer, concluding the May 9 loan date is excluded from the 30-day count so the crash fell within day 30.
The Appellate Court affirmed; the Supreme Court granted certification limited to whether the loan date counts as the first day of the 30-day period.
The Supreme Court affirmed the Appellate Court: (1) "days" in § 14-60(a) means full calendar days (midnight–midnight); (2) the day of the loan (a fraction of a day) is excluded under the longstanding Weeks rule; and (3) parties' subjective intent cannot override statutory construction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the date the dealer loaned the plate (May 9) counts as day 1 of the § 14-60(a) 30-day limit	May 9 is the loan date and should be counted as the first day	"Days" means full calendar days; the loan occurred for only a fraction of May 9, so it should be excluded	Exclude the loan date; the statute measures "days" as full 24-hour calendar days and the day of the act is excluded (Weeks rule). The crash on June 8 was within 30 days.
Whether the parties’ intent / terms of the loan agreement can create a factual issue to include May 9 in the 30-day computation	Loan agreement and CFO testimony show parties intended the loan to start May 9, so a genuine issue of fact exists	Computation of the statutory 30-day period is a matter of statutory construction governed by legislative intent, not parties’ subjective intent	Parties’ intent is irrelevant to statutory time computation; no genuine factual dispute defeats summary judgment.

Weeks v. Hull, 19 Conn. 376 (Conn. 1849) (established rule excluding the day of the act from computation of future time periods)
Miner v. Goodyear Glove Mfg. Co., 62 Conn. 410 (Conn. 1892) (day is a whole 24-hour period and law rejects fractions of a day)
Secretary of Office & Policy & Management v. Employees’ Review Board, 267 Conn. 255 (Conn. 2004) (unqualified "day" construed as calendar day)
The Pocket Veto Case, 279 U.S. 655 (U.S. 1929) (federal recognition that unqualified "days" mean calendar days)
Austin, Nichols & Co. v. Gilman, 100 Conn. 81 (Conn. 1923) (applied Weeks rule to statutory time computation)
Krajniak v. Wilson, 157 Conn. 126 (Conn. 1968) (contrast: statutory language specifying "on the date of" can render Weeks rule inapplicable)