Halpern v. Board of Education

495 A.2d 264, 196 Conn. 647, 26 Educ. L. Rep. 665, 1985 Conn. LEXIS 830
CourtSupreme Court of Connecticut
DecidedJuly 16, 1985
Docket11549
StatusPublished
Cited by174 cases

This text of 495 A.2d 264 (Halpern v. Board of Education) 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
Halpern v. Board of Education, 495 A.2d 264, 196 Conn. 647, 26 Educ. L. Rep. 665, 1985 Conn. LEXIS 830 (Colo. 1985).

Opinion

Arthur H. Healey, J.

This appeal involves the prior pending action doctrine. The plaintiff, who had been employed by the defendant as a teacher, instituted an administrative appeal under General Statutes § 10-151 (f)1 from the termination of her employment. [649]*649While that action was pending, the plaintiff, seeking a writ of mandamus and a declaratory judgment, instituted a second, separate action against the same defendant. The factual allegations in both actions are substantially identical, and the trial court, finding that the “ultimate goals in both cases are not dissimilar,” granted the defendant’s motion to dismiss the later action under the prior pending action rule. The plaintiff appeals. We find no error.

The present appeal arises from our remand in Lee v. Board of Education, 181 Conn. 69, 434 A.2d 333 (1980). The plaintiff2 was a tenured teacher employed by the defendant, the city of Bristol board of education, which discharged her from that position in 1974. Thereafter, pursuant to the Teacher Tenure Act; see General Statutes § 10-151; the plaintiff appealed from that decision to the Court of Common Pleas, which dis[650]*650missed the appeal. She then appealed to this court, and in Lee v. Board of Education, supra, we held that “a tenured teacher discharged for cause under General Statutes § 10-151 (b) is entitled, as a matter of constitutional law, to a written statement of the decision reached, the reasons for the determination, and a fair summary of the evidence relied upon.” Id., 79. Because these requirements had not been met, we set aside the trial court’s judgment and the matter was remanded “with direction to return the case to the board for further proceedings consistent with this opinion.” Id., 84.

Thereafter in November, 1980, the defendant board, comprised entirely of members who had not participated in the previous 1974 termination proceeding, “issued ‘findings and conclusions,’ based upon the record” of the plaintiff’s 1974 pretermination hearing, to substantiate the plaintiff’s discharge. On December 4, 1980, the plaintiff appealed those “actions and decision” of the defendant to the Superior Court where that action (the first action) is still pending. See General Statutes § 10-151 (f). While the first action was pending, the plaintiff also initiated this second action which forms the subject of this particular appeal before us. Although the allegations of these two complaints, except for one sentence in each,3 are identical, the prayers for relief differ somewhat. In the first action, [651]*651the plaintiff alleged aggrievement and sought a reversal of the defendant’s “final decision,” a declaration “that the action of said Board in attempting to terminate [the] plaintiff’s contract of employment . . . [is] invalid,” and an order “that this matter be remanded to the Board for a determination of the amount of back wages and benefits owed to [the] plaintiff by [the] defendant.” The prayer for relief in the plaintiff’s second action sought both a writ of mandamus and a declaratory judgment to the effect that the plaintiff either be reinstated to her previous position as a tenured teacher or be granted a “new hearing” pursuant to General Statutes § 10-151 “to determine whether [the] plaintiff should be terminated from her position with [the] defendant as of the date of the determination resulting from that new hearing” and that the defendant also must hold a “hearing” for the purpose of determining “the amount of back wages and benefits” owed to the plaintiff by the defendant “for the period of time from her unlawful termination to the date when she is either reinstated or lawfully terminated . . . .”

Alleging lack of subject matter jurisdiction, the defendant filed a motion to dismiss the second action on the ground, inter alia, that it was “virtually identical to the one filed on December 4, 1980.” See Practice Book §§ 142,143,145. The trial court granted the defendant’s motion to dismiss and, in its memorandum of decision, stated: “The parties in both cases are the same and the allegations raised in the appeal and in the instant action are mutual. Beyond this, both matters were filed and are pending in the same jurisdiction and venue. The court is mindful that the remedy sought in the instant matter is dissimilar to that in the earlier case. This is of no significant consequence. The ultimate goals in both cases are not dissimilar.” The plaintiff appeals from this dismissal, but nevertheless [652]*652concedes in her brief that, if the first appeal “proceeds to a final decision on the merits, this action will be unnecessary.”

“It has long been the rule that when two separate lawsuits are ‘virtually alike’ the second action is amenable to dismissal by the court. Henry F. Raab Connecticut, Inc. v. J. W. Fisher Co., 183 Conn. 108, 112, 438 A.2d 834 (1981).” Solomon v. Aberman, 196 Conn. 359, 382, 493 A.2d 193 (1985). The prior pending action doctrine has evolved as a “rule of justice and equity”;4 Hatch v. Spofford, 22 Conn. 485, 494 (1853); and retains its vitality in this state, in which “joinder of claims and of remedies is permissive rather than mandatory.” (Citations omitted.) Solomon v. Aberman, supra.

We have explicated the prior pending action doctrine as follows: “ ‘ “The pendency of a prior suit of the same character, between the same parties, brought to obtain the same end or object, is, at common law, good cause for abatement. It is so, because there cannot be any reason or necessity for bringing the second, and, therefore, it must be oppressive and vexatious.” This is “a rule of justice and equity, generally applicable, and always, where the two suits are virtually alike, and in [653]*653the same jurisdiction.” Hatch v. Spofford, [supra, 494]; Cahill v. Cahill, 76 Conn. 542, 547, 57 Atl. 284 [1904].’ Dettenborn v. Hartford-National Bank & Trust Co., 121 Conn. 388, 392, 185 A. 82 (1936); see Zachs v. Public Utilities Commission, 171 Conn. 387, 391-92, 370 A.2d 984 (1976). ‘The rule forbidding the second action is not, however, one “of unbending rigor, nor of universal application, nor a principle of absolute law . . . .” Hatch v. Spofford, [supra].’ Farley-Harvey Co. v. Madden, 105 Conn. 679, 682, 136 A. 586 (1927); see Brochin v. Connecticut Importing Co., 137 Conn. 350, 352, 77 A.2d 336 (1950); Dettenborn v. Hartford-National Bank & Trust Co., supra, 393.” Henry F. Raab Connecticut, Inc. v. J. W. Fisher Co., supra, 112-13. We must examine the pleadings to ascertain whether the actions are “virtually alike.” See Solomon v. Aberman, supra, 383.

The allegations contained in the plaintiff’s complaints in both actions are identical, and, as we have already explained, the actions arise from the same factual background.

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Bluebook (online)
495 A.2d 264, 196 Conn. 647, 26 Educ. L. Rep. 665, 1985 Conn. LEXIS 830, Counsel Stack Legal Research, https://law.counselstack.com/opinion/halpern-v-board-of-education-conn-1985.