Ayala v. Smith

671 A.2d 345, 236 Conn. 89, 1996 Conn. LEXIS 32
CourtSupreme Court of Connecticut
DecidedFebruary 20, 1996
Docket15193
StatusPublished
Cited by57 cases

This text of 671 A.2d 345 (Ayala v. Smith) is published on Counsel Stack Legal Research, covering Supreme Court of Connecticut primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ayala v. Smith, 671 A.2d 345, 236 Conn. 89, 1996 Conn. LEXIS 32 (Colo. 1996).

Opinion

NORCOTT, J.

The principal issue raised by this appeal is whether, under our rules of practice, a plaintiff may maintain an action against a defendant whose identity is unknown to the plaintiff and is therefore referred to as “John Doe.” Because we determine that the plaintiffs claim is moot, however, we do not reach this issue and dismiss the appeal for lack of subject matter jurisdiction.

The relevant factual and procedural background is as follows. On August 25,1992, the automobile in which the plaintiff, William Ayala, was a passenger was involved in an accident at the intersection of Broad Street and Park Street in the city of Hartford. The owner and operator of the vehicle in which the plaintiff was riding was Francisco Javier. The operator of the other vehicle involved in the accident, which allegedly made an improper left turn in front of Javier’s vehicle, abandoned his vehicle, fled the scene and has never been identified.1 The plaintiff learned shortly after the accident that the other vehicle had been leased from Agency Rent-A-Car (Agency) by Gisele Smith.

On July 9,1993, the plaintiff commenced a negligence action against Smith, the unknown driver of the other vehicle identified in the writ as “John Doe,” Agency and Javier to recover for injuries he had sustained in the accident. Agency filed a cross complaint against Smith, Doe and Javier.2 On March 16, 1994, Robert E. Young, the attorney for Agency, acting on behalf of Doe, filed a motion to dismiss the plaintiffs action as against Doe, on the ground that the trial court lacked personal jurisdiction over Doe because: (1) the rules of practice [91]*91do not permit a plaintiff to proceed against an unknown defendant; and (2) service of process had never been properly effectuated against Doe.3 Subsequently, the plaintiff deposed Smith, who could not recall whether, or to whom, she might have loaned the vehicle that she had rented from Agency.4 On August 30, 1994, the trial court granted the motion to dismiss the plaintiffs action as to Doe, citing “insufficient service of process” as the ground. The plaintiff appealed from the judgment of the trial court to the Appellate Court and we transferred the case to this court pursuant to General Statutes § 51-199 (c) and Practice Book § 4023.

On appeal, the plaintiff urges this court to adopt a rule that would permit a party to institute and maintain an action against an unidentified person, under a fictitious name, for a “reasonable time period” within which to attempt to discover that person’s identity.5 With regard to service of process, the plaintiff claims that Doe was properly served by the delivery of copies of the writ, summons and complaint to the commissioner of motor vehicles pursuant to General Statutes § 52-[92]*9263,6 and to Doe at Smith’s last known address. Doe argues that the rule proposed by the plaintiff is unsupported by authority in this state regarding the use of fictitious names in a lawsuit and, with regard [93]*93to service of process on Doe, that § 52-63 does not contemplate service on the commissioner of motor vehicles on behalf of an unknown party, and thus Doe was never properly served. We do not reach the merits of the parties’ arguments, however, because, in light of certain concessions made by the plaintiff during oral argument in this court, we determine that the case is moot and, accordingly, we have no jurisdiction to entertain the appeal.

Mootness implicates the court’s subject matter jurisdiction and is thus a threshold matter for us to resolve. See Goodson v. State, 228 Conn. 106, 114, 635 A.2d 285 (1993), on appeal after remand, 232 Conn. 175, 653 A.2d 177 (1995); Gagnon v. Planning Commission, 222 Conn. 294, 297, 608 A.2d 1181 (1992); Sadlowski v. Manchester, 206 Conn. 579, 583, 538 A.2d 1052 (1988). The issue of mootness often arises in the latter stages of the appeal process, when actions of the parties have resolved the underlying dispute between them. See Sobocinski v. Freedom of Information Commission, 213 Conn. 126, 134-35, 566 A.2d 703 (1989). “It is a well-settled general rule that the existence of an actual controversy is an essential requisite to appellate jurisdiction; it is not the province of appellate courts to decide moot questions, disconnected from the granting of actual relief or from the determination of which no practical relief can follow.” (Internal quotation marks omitted.) St. Pierre v. Solnit, 233 Conn. 398, 400-401, 658 A.2d 977 (1995). “An actual controversy must exist not only at the time the appeal is taken, but also through[94]*94out the pendency of the appeal.” Sobocinski v. Freedom of Information Commission, supra, 134-35. “When, during the pendency of an appeal, events have occurred that preclude an appellate court from granting any practical relief through its disposition of the merits, a case has become moot.” (Internal quotation marks omitted.) Loisel v. Rowe, 233 Conn. 370, 378, 660 A.2d 323 (1995); In re Romance M., 229 Conn. 345, 357, 641 A.2d 378 (1994); see also Sobocinski v. Freedom of Information Commission, supra, 134; Nader v. Altermatt, 166 Conn. 43, 56, 347 A.2d 89 (1974); Southbury v. American Builders, 162 Conn. 633, 634, 295 A.2d 566 (1972). The determination of whether a claim has become moot is fact sensitive, and may include the representations made by the parties at oral argument. Cf. Loisel v. Rowe, supra, 378.

At oral argument, the plaintiff conceded that: (1) at the time the trial court granted the motion to dismiss his claims against Doe, a “reasonable time” had already passed for discovery of the unknown driver’s identity, further inquiry into Doe’s identity at that point would likely have been fruitless and, in all likelihood, Doe will never be identified; and (2) with respect to the relief sought in the underlying action for personal injuries, the plaintiff recently had reached a satisfactory financial settlement with his uninsured motorist insurance carrier, and he could not, therefore, recover from Doe even if Doe’s identity were to be discovered in the future. Further, the plaintiff specifically conceded that, in light of these facts, even if he were to prevail on the merits of his appeal, this court could afford him no practical relief. It is clear, therefore, that, by his own admissions, the plaintiff has no present interest in pursuing Doe other than an academic one, and his claim falls squarely within the mootness doctrine.

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Cite This Page — Counsel Stack

Bluebook (online)
671 A.2d 345, 236 Conn. 89, 1996 Conn. LEXIS 32, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ayala-v-smith-conn-1996.