Wilton Meadows Ltd. Partnership v. Coratolo, 14 A.3d 982

Wilton Meadows LP provided nursing home care and related services to Carmen Coratolo from August 14, 2006 to October 10, 2007, including daily living assistance, nursing care, meals, room and board, and medication administration.
From August 14, 2006 until March 7, 2007 the decedent had no medical insurance or Medicaid coverage; Medicaid benefits were first received on March 8, 2007 to cover expenses.
Unpaid charges amounted to $60,795.32 accruing during the period before Medicaid coverage began.
The decedent died on October 25, 2007.
The plaintiff filed suit on April 21, 2008 under General Statutes § 46b-37 (b)(4) seeking to recover nursing home expenses from the defendant as a spouse.
The trial court granted summary judgment for the defendant, ruling that nursing home care did not qualify as an 'article' purchased or as 'support of the family' under § 46b-37 (b)(4).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether nursing home expenses fall within § 46b-37 (b)(4).	Wilton Meadows argues nursing home care is an 'article' and part of 'support of the family'.	Coratolo contends nursing home expenses are not included in § 46b-37 (b)(4).	Nursing home expenses are excluded from § 46b-37 (b)(4).
Whether the trial court should have treated the summary judgment as a motion to strike.	Plaintiff contends the court should have allowed amendment by striking the motion and repleading.	Defendant asserts the motion challenged legal sufficiency; repleading would be futile.	Summary judgment proper; not treated as a motion to strike.
Whether there were genuine issues of material fact precluding summary judgment.	Plaintiff claims factual disputes existed about the scope of § 46b-37 (b)(4).	Court found the issue was strictly a legal interpretation of the statute, with no material fact in dispute.	No genuine issues of material fact; the decision rests on the statute's interpretation.

Katz v. Cohn, 122 Conn. 338 (1937) (home care services under family support duty; limited relevance to article scope)
Grady v. Somers, 294 Conn. 324 (2009) (statutory interpretation and use of § 1-2z guidance)
Yale Univ. Sch. of Med. v. Collier, 206 Conn. 31 (1988) (strict construction of spousal liability statute in derogation of common law)
Sokaitis v. Bakaysa, 293 Conn. 17 (2009) (harmonious and consistent statutory interpretation within broader scheme)
Liberty Mut. Ins. Co. v. Lone Star Indus., Inc., 290 Conn. 767 (2009) (summary judgment standard and burden on movant/opponent)
American Progressive Life & Health Ins. Co. of N.Y. v. Better Benefits, LLC, 292 Conn. 111 (2009) (treatment of pleading defects and adequacy of legal theories)