18 Conn. L. Rptr. 271 | Conn. Super. Ct. | 1996
On July 17, 1996, Elk filed this motion to strike Seiling's fifth count of the complaint along with the claim for punitive damages and attorney's fees, alleging that Seiling failed to allege facts sufficient to state a violation of CUTPA and failed to allege a general practice or course of conduct as required by CUTPA.
On August 13, 1996, Seiling filed an amended complaint, without objection, to correct numbering errors in the fifth count of her original complaint, and by agreement of the parties, Elk's motion to strike, is now directed to Seiling's amended complaint.
— I —
Elk in its motion to strike, asserts that allegations of a breach of statutory warranties alone are not sufficient to support a CUTPA cause of action, and furthermore, even if a breach of statutory warranties alone constituted a CUTPA violation, Seiling has not made any factual allegations that Elk engaged in "immoral, unethical, oppressive or unscrupulous conduct" as required by the "cigarette rule" set forth inJacobs v. Healy Ford-Subaru, Inc.,
— II —
Seiling claims that allegations of a breach of warranty are sufficient to support a CUTPA cause of action relying primarily on Krawiec v. Blake Manor Development Corp.,
The other cases cited by Seiling also provide little support for her proposition. Notably, Web Press Services Corp. v.New London Motors, Inc.,
The majority of Superior Court decisions hold that breach of warranty allegations generally will not support a CUTPA cause of action. See Agento v. Patient Aide Center, Inc., Superior Court, judicial district of Stamford-Norwalk at Stamford, Docket No. 118943 (August 12, 1993, Rush, J.,
A showing of aggravated circumstances in addition to a breach of warranty, however, may support a claim for a CUTPA violation. "A simple breach of contract, even if intentional, does not amount to a violation of [CUTPA], a claimant must showsubstantial aggravating circumstances attending the CT Page 9586 breach to recover under the Act." Berlingo v. Griffith Ford,Inc., Superior Court, judicial district of Stamford-Norwalk at Stamford, Docket No. 146728 (February 28, 1996, Ryan, J.). These aggravated circumstances must demonstrate that the defendant's conduct was somehow "immoral, unethical, unscrupulous, or offensive to public policy." Id.
In the present case, Seiling does not allege any additional aggravating circumstances by which to show that Elk's conduct was "immoral, unethical, unscrupulous, or offensive to public policy." and accordingly, the breach of warranty theory is insufficient to sustain a CUTPA claim.
— III —
Seiling claims nevertheless that her allegations of Elk's breach, creation of a dangerous situation, notice and failure to remedy the situation sufficiently support a CUTPA cause of action, relying on several decisions including Levesque v.Williamsburg Associates, Superior Court, judicial district of Hartford-New Britain at Hartford, Docket No. 526235 (February 17, 1995, Sheldon, J.). That decision which upheld a CUTPA claim based on a defendant landlord's violation of General Statutes §
In Ortiz v. Donmar Development Corp., Superior Court, judicial district of New Haven at New Haven, Docket No. 347957 (December 23, 1994, Zoarski, J.), the court concluded that allegations that the defendant had not complied with its own proposed subdivision plan approved by the Town that a hazardous condition resulted from the defendant's action; namely that "large rocks and boulders began to fall from the rear of [plaintiffs' property] striking their house . . ." and that the defendant has refused the plaintiffs' demand that it correct the hazardous condition could, if proven, rise to the level of unethical or unscrupulous conduct encompassed under CUTPA."
In the present case, Seiling alleges that "[d]uring the summer of 1995, the shingles began breaking apart, falling from, and leaving large gaps in, the roof on plaintiff's residence. Shingles continue to fall from the roof, to the plaintiff's damage and to the danger of others. The roof began to leak, causing damage to the interior walls, beams, and furnishings. The CT Page 9587 roof continues to leak to the present." Even under the reasoning of Ortiz these allegations of falling shingles do not paint a sufficiently hazardous situation to invoke CUTPA.
Motion to Strike Fifth Count as well as claims for punitive damages and attorney's fees is granted.
Jerry Wagner Trial Judge Referee