Isaac v. Truck Service, Inc.

752 A.2d 509, 253 Conn. 416, 2000 Conn. LEXIS 178
CourtSupreme Court of Connecticut
DecidedJune 6, 2000
DocketSC 16109
StatusPublished
Cited by47 cases

This text of 752 A.2d 509 (Isaac v. Truck Service, Inc.) 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
Isaac v. Truck Service, Inc., 752 A.2d 509, 253 Conn. 416, 2000 Conn. LEXIS 178 (Colo. 2000).

Opinion

Opinion

BORDEN, J.

The issue in this certified appeal is whether the doctrine of claim preclusion operates to bar a personal injury action arising out of an automobile accident, filed on the regular docket of the trial court, that is preceded by a judgment for property damage to [418]*418the plaintiffs automobile on the small claims docket of the trial court. The defendants appeal from the judgment of the Appellate Court rejecting their claim that the doctrine of claim preclusion barred this action by the plaintiff.1 Isaac v. Truck Service, Inc., 52 Conn. App. 545, 557, 727 A.2d 755 (1999). We conclude that the doctrine of claim preclusion should not apply in these circumstances. Accordingly, we affirm the judgment of the Appellate Court.

The plaintiff, Mary G. Isaac, brought this personal injury action against the defendants, Truck Service, Inc. (Truck Service), and Mary Ann West,2 for injuries arising out of an automobile accident on September 28, 1993. The trial court rejected, as a matter of law, the special defense that the plaintiffs action was barred by the doctrine of claim preclusion based upon the plaintiffs prior small claims judgment against Truck Service for property damage to her automobile arising out of the same accident.3 Following a jury verdict for the defendants, the trial court rendered judgment for the defendants on the verdict.

The plaintiff appealed to the Appellate Court, which determined that a new trial was required because the trial court, Rittenband, J., improperly had permitted the defendants to amend their answer to the complaint during closing arguments. The Appellate Court also rejected the defendants’ alternate ground for affirming the judgment, namely, the application of the doctrine of claim preclusion. Accordingly, the Appellate Court [419]*419reversed the judgment of the trial court and ordered a new trial. Id., 557. This certified appeal followed.

As stated by the Appellate Court, the facts relevant to this appeal are undisputed. On February 25, 1992, the plaintiff was driving her car on Interstate 91 in Windsor when there was a collision with another vehicle that the plaintiff claimed to be a truck owned by Truck Service. Id., 547. “After the accident occurred, the plaintiff immediately notified the Connecticut state police. She notified Truck Service of the accident the next day. On March 2, 1992, Truck Service had the property damage to the plaintiffs vehicle appraised at $1422.58. After her attempts to resolve her claim with Truck Service failed, the plaintiff initiated a small claims action against Truck Service in July, 1992. The plaintiff was able to reach a settlement agreement with Truck Service’s liability insurance carrier in September, 1992. The insurance carrier issued settlement checks to the plaintiff but stopped payment on the drafts soon thereafter. The plaintiff, therefore, proceeded to a hearing in damages in small claims court and was awarded a judgment of $1422.58 plus costs.

“At the time she instituted her small claims action against the defendants, the plaintiff had not yet seen a physician for the injuries she alleges that she had sustained in the accident. Although she was experiencing back and neck pain, the plaintiff treated herself with over-the-counter pain relievers. On April 23, 1993, the plaintiff sought treatment from an orthopedic surgeon when the over-the-counter remedies ceased providing relief. The physician advised the plaintiff that she had underlying orthopedic conditions that were, in his opinion, made substantially and materially worse by the accident. The plaintiff commenced the present action against West and Truck Service in September, 1993, seeking damages for the personal injuries she had sustained.” Id., 554.

[420]*420The Appellate Court declined to apply the doctrine of claim preclusion on the factual basis that: the plaintiff had sought to secure compensation for her property damage within two weeks of the accident; at that time, she believed that her injuries could be remedied without medical attention; she did not learn until more than one year later that her injuries were serious enough to require surgery; and she brought this action for her injuries within six months thereafter. Id., 556-57. On the basis of these facts, the Appellate Court held that “our social policy of providing a means of redress for personal injuries outweighs the need for finality of the small claims judgment.” Id., 557.

The defendants claim that the Appellate Court, in rejecting their alternate ground for affirmance of the trial court’s judgment, improperly failed to apply settled principles of claim preclusion. Although we disagree with the route by which the Appellate Court reached its conclusion, we agree with that court that the doctrine of claim preclusion does not apply to this case. We conclude that the doctrine does not apply to a claim for personal injuries arising out of an automobile accident, filed on the regular docket of the Superior Court, where the parties have litigated the question of property damage arising out of the same accident on the small claims docket of the court.

It is difficult to dispute — and the plaintiff does not dispute — the defendants’ contention that, pursuant to the ordinary application of the general principles of claim preclusion, the plaintiffs claim would be barred. Under those principles, a valid, final judgment rendered on the merits by a court of competent jurisdiction is an absolute bar to a subsequent action between the same parties, or those in privity with them, upon the same claim or demand. Slattery v. Maykut, 176 Conn. 147, 156-57, 405 A.2d 76 (1978). Furthermore, the doctrine of claim preclusion, as opposed to issue preclu[421]*421sion, bars not only subsequent relitigation of a claim previously asserted, but subsequent relitigation of “any claims relating to the same cause of action which were actually made or which might have been made.” Orselet v. DeMatteo, 206 Conn. 542, 545, 539 A.2d 95 (1988). In addition, for these purposes whether the subsequent claim relates to the same cause of action is to be determined by the transactional test, which is measured by “the ‘group of facts which is claimed to have brought about an unlawful injury to the plaintiff,’ ” and which also states that “ ‘[ejven though a single group of facts may give rise to rights for several different kinds of relief, it is still a single cause of action.’ ” Duhaime v. American Reserve Life Ins. Co., 200 Conn. 360, 365, 511 A.2d 333 (1986). Moreover, the doctrine applies even where the prior litigation was a small claims action. Orselet v. DeMatteo, supra, 546 (prior small claims judgment in favor of plaintiff for car rental expense bars subsequent action for property damage to plaintiffs car). Finally, as the defendants point out, § 24 of the Restatement (Second) of Judgments reiterates these principles, and illustrates them by indicating that they apply to a subsequent claim for personal injury preceded by a prior small claims judgment for property damage to a vehicle, arising out of the same accident.

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Bluebook (online)
752 A.2d 509, 253 Conn. 416, 2000 Conn. LEXIS 178, Counsel Stack Legal Research, https://law.counselstack.com/opinion/isaac-v-truck-service-inc-conn-2000.