State v. Henderson, 140 Conn. App. 672

The State of Connecticut filed a nuisance abatement action under §19a-343 against Henderson, Henderson, Kuhl, Cityscape Real Estate, and the 2041 North Broad Street property (the 2041 Club).
A September 10, 2009 stipulation for judgment required the club to remain closed and restricted future uses; the city was not a signatory to the stipulation.
On October 16, 2009, Hendersons agreed to sell the 2041 Club to Daenekindt for $400,000, but the sale was not consummated after city officials refused approval for an adult business at that property.
Henderson moved to enforce the stipulation; the trial court denied without a written decision and denied post-trial motions.
On appeal, the court held there was no evidence that the city was bound by the stipulation or assented to it, and that enforcing a contract binding the city would require showing the city was a party or had manifested assent; the city was not canvassed at the stipulation proceeding.
The judgment was affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Standing to enforce the stipulation	State contends the relevant party could enforce the stipulation.	Henderson lacked standing to enforce the stipulation.	Affirmed: no proper standing shown.
Whether the city was bound by the stipulation	City not bound by contract to which it did not assent.	City argued it could be bound to the stipulation.	Affirmed: city not bound by the stipulation.
Whether the trial court properly canvassed bound parties	Court canvassed those who agreed to be bound.	City not canvassed because not bound.	Affirmed: city not bound and not canvassed.

FCM Group, Inc. v. Miller, 300 Conn. 774 (2011) (limits on when a non-party can be bound to a contract)
State v. Wahab, 122 Conn. App. 537 (2010) (adequacy of record for appellate review when self-representation)