Wood v. CLUB, LLC, 134 Conn. App. 768

Patrick Wood sued Club, LLC (Thirsty Turtle) for injuries from an assault at a March 24, 2007 birthday party; jury awarded $300,000 total ($60,000 economic, $240,000 noneconomic).
Plaintiff alleged negligent and reckless supervision of premises by the nightclub's security staff and management.
The incident occurred after a private party was opened to the public; male patrons engaged in unwanted dancing and advances toward women, prompting complaints to bar staff.
Security manager Boehmcke identified the assailant; no arrest was made; plaintiff suffered partial permanent impairment.
The defendant appealed, challenging evidentiary rulings (expert testimony, intoxication evidence, reputation evidence) and several jury instructions (third-party liability, future medical expenses, scope of risk).
The trial court denied post-trial motions; the appellate court affirmed the judgment for Wood.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of plaintiff's bar security expert	DePalma possessed requisite knowledge for bar security testimony.	DePalma lacked qualifications to testify as an expert.	Court did not abuse discretion; DePalma qualified.
Admission of testimony on plaintiff's intoxication	Intoxication could affect credibility; admissible.	Intoxication evidence relevant to credibility and memory.	Court properly excluded; harm not shown.
Admission of testimony on defendant's reputation	Reputation evidence relevant to character before the jury.	Evidence was improper and hearsay-like.	Claim not preserved; not addressed on the merits.
Jury instruction on third-party liability	Should have instructed on liability for third parties to address foreseeability.	Omission prevented proper consideration of same-general-nature risk.	Charge, viewed as a whole, adequately conveyed proximate-cause principles; no reversible error.
Future medical expenses instruction	Evidence supported ongoing treatment and impairment; instruction warranted.	No evidence future treatment was necessary.	Court's instruction on future medical expenses supported by trial evidence.
Scope of risk and causation	Harm from assault was within the risk created by inadequate security.	Harm not within the scope of foreseeable risk.	Evidence was sufficient to show the plaintiff's injury within the scope of risk.

Stewart v. Federated Dept. Stores, Inc., 234 Conn. 597, 662 A.2d 753 (1995) (third-party liability proximate-cause framework; same-general-nature risk)
Godwin v. Danbury Eye Physicians & Surgeons, P.C., 254 Conn. 131, 757 A.2d 516 (2000) (jury instruction adequacy; standard for reviewing instructions)
State v. Gupta, 297 Conn. 211, 998 A.2d 1085 (2010) (relevance and admissibility of evidence; balancing probative value and harm)
Beverly Hills Concepts, Inc. v. Schatz & Schatz, Ribicoff & Kotkin, 247 Conn. 48, 717 A.2d 724 (1998) (expert qualification without specific credentials; greater knowledge than layperson)
Pestey v. Cushman, 259 Conn. 345, 788 A.2d 496 (2002) (preservation of evidentiary-error claims; standard of review)
New Hartford v. Connecticut Resources Recovery Authority, 291 Conn. 433, 970 A.2d 592 (2009) (abuse-of-discretion standard; harm requirement for evidentiary rulings)
Stewart v. Federated Dept. Stores, Inc., 234 Conn. 597, 662 A.2d 753 (1995) (duty regarding third-party criminal acts; foreseeability and scope of risk)