Kim Chai Mock v. Mohegan Tribal Gaming Authority

11 Am. Tribal Law 344
CourtMohegan Gaming Disputes Trial Court
DecidedApril 25, 2013
DocketNo. GDTC-T-12-105-PMG
StatusPublished

This text of 11 Am. Tribal Law 344 (Kim Chai Mock v. Mohegan Tribal Gaming Authority) is published on Counsel Stack Legal Research, covering Mohegan Gaming Disputes Trial Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Kim Chai Mock v. Mohegan Tribal Gaming Authority, 11 Am. Tribal Law 344 (Mo. 2013).

Opinion

MEMORANDUM OF DECISION ON DEFENDANT’S MOTION TO STRIKE

GUERNSEY, C.J.

This action arises out of a horrific bus accident that took place on March 12, 2011 on Interstate 95 in New York City when a bus owned and operated by tour bus services World Wide Tours of Greater New York, LTD and/or World Wide Travel of Greater NY, LTC departed from the travel lane, impacted with a travel barrier, and subsequently collided with a support pole for an overhead sign, resulting in the [345]*345deaths of, or serious injury to, the sixteen passengers whose claims are incorporated into this litigation.1 It is alleged that the MTGA had entered into a partnership or joint venture with the tour bus services and another seller of tour bus tickets, offering certain benefits to encourage the attendance at the Mohegan Sun Casino, and marketed the partnerships as Mohegan Sun Asian Bus Lines, particularly to the Asian community.2

Plaintiffs’ 51 count complaint is based on three legal theories, with Counts 1-16 seeking to impose liability on the Mohegan Tribal Gaming Authority pursuant to a theory of partnership or joint venture (with one Count for each Plaintiff). Counts 17-32 are predicated on a theory of partnership or joint venture by estoppel, and Counts 33-51 are based on a variety of claims of negligence. The instant Motion to Strike is addressed only to Counts 17-32, and asserts that, under Connecticut law, partnership or joint venture by estop-pel cannot serve as the basis for imposing vicarious liability in tort, and that under Conn. Gen.Stat. § 34-329 such liability exists only in favor of those who give credit to one who permits others to hold him out as a partner. Davies v. General Tours, Inc., 63 Conn.App. 17, 31-32, 774 A.2d 1063 (2001).

In reply, the Plaintiffs argue that this is a conflict of laws case, and that under a significant contacts analysis (and, of course, under the doctrine of lex loci de-licti ) New York law should be applied to this accident. Simaitis v. Flood, 182 Conn. 24, 33, 437 A.2d 828 (1980). Plaintiffs maintain, without citation to authority, that tort liability may be imposed vicariously under New York law based on partnership or joint venture by estoppel, a position not conceded by the Defendant.

In ruling on a motion to strike a complaint, the Court must construe the complaint most favorably to the Plaintiff. Dodd v. Middlesex Mutual Assurance Co., 242 Conn. 375, 378, 698 A.2d 859 (1997). This has repeatedly been emphasized by the Connecticut Supreme and Appellate Courts:

Thus, [i]f facts provable in the complaint would support a cause of action, the motion to strike must be denied.... Moreover, we note that [w]hat is necessarily implied [in an allegation] need not be expressly alleged.... It is fundamental that in determining the sufficiency of a complaint challenged by a defendant’s motion to strike, all well-pleaded facts and those facts necessarily implied from the allegations are taken as admitted .... Indeed, pleadings must be construed broadly and realistically, rather than narrowly and technically. (Internal quotation marks omitted.)

Violano v. Fernandez, 88 Conn.App. 1, 4-5, 868 A.2d 69 (2005), aff'd, 280 Conn. 310, 907 A.2d 1188 (2006). Inasmuch as the issue of what is the law of a foreign (i.e., non-Connecticut) jurisdiction raises an issue of fact,3 in ruling on the instant motion to strike the viability of such a cause of action under New York law will be taken as admitted.4

[346]*346 DISCUSSION

It cannot be doubted that the Connecticut Appellate Court has shown extreme reluctance to recognize the doctrine of apparent authority, of which partnership by estoppel is an example, as a basis for imposing liability for tortious misconduct. Such a claim was summarily dismissed in an action seeking to hold a number of religious institutions liable for damages for sexual contact between a defendant priest/psychologist and a patient receiving pastoral, spiritual and psychological counseling. The Plaintiff argued that the defendants held out the priest/psychologist as a trustworthy, ethical, respectable priest-clinical psychologist on which representation the Plaintiff relied to her detriment. While recognizing that other states have used the doctrine of apparent authority for imposing vicarious liability for harm caused by the lack of care of skill of the servant or agent, the Appellate Court summarily dismissed such a claim, stating, without further explanation, that [i]n Connecticut, however, the doctrine of apparent authority has never been used in such a manner. Mullen v. Horton, 46 Conn.App. 759, 771-72, 700 A.2d 1377 (1997).

A claim of tortious liability based on partnership by estoppel was directly addressed by the Appellate Court in Davies v. General Tours, Inc., supra, where the plaintiff attempted to predicate liability, inter alia, on theories of partnership by estoppel and apparent agency or agency by estoppel. Once again, the Appellate Court was not persuaded, citing Mullen v. Horton, supra, to dispose of the apparent agency or agency by estoppel theory of liability, and limiting the common law principle of partnership by estoppel to situations involving the advancing of credit.5 Lower court cases imposing liability in cases of apparent agency were distinguished on grounds that the independent contractors were held out to be employees, not partners. Davies v. General Tours, Inc., supra at 32-33, 774 A.2d 1063. The opportunity for proper appellate resolution of these issues presented by the Connecticut Supreme Court’s granting of certification, 256 Conn. 926, 776 A.2d 1143 (2001), was removed by the withdrawal of the appeal on October 18, 2001.

This state of affairs was recently reaffirmed by the Appellate Court when it reversed a finding of vicarious liability by a trial court:

Connecticut, nevertheless, has yet to apply the doctrine of apparent authority to allow for a principal to be held liable to a third person who was harmed by the tortious conduct of a person held out as the principal’s agent.
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[347]*347In the present case, the claims against AAMCO sound in tort and are based on the tortious conduct of Drive Train, which the plaintiff alleges AAMCO held out as its agent. Because this court has held that the doctrine of apparent authority cannot be used to hold a principal liable for the tortious actions of its alleged agent, we conclude that the trial court erred in determining that Drive Train had apparent authority to bind AAMCO.

L and V Contractors LLC v.

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Related

Simaitis v. Flood
437 A.2d 828 (Supreme Court of Connecticut, 1980)
Violano v. Fernandez
868 A.2d 69 (Connecticut Appellate Court, 2005)
Violano v. Fernandez
907 A.2d 1188 (Supreme Court of Connecticut, 2006)
Cavezza v. Gardner
176 A.D.2d 911 (Appellate Division of the Supreme Court of New York, 1991)
O'Connor v. O'Connor
519 A.2d 13 (Supreme Court of Connecticut, 1986)
Dodd v. Middlesex Mutual Assurance Co.
698 A.2d 859 (Supreme Court of Connecticut, 1997)
Mullen v. Horton
700 A.2d 1377 (Connecticut Appellate Court, 1997)
Davies v. General Tours, Inc.
774 A.2d 1063 (Connecticut Appellate Court, 2001)
Long v. Mohegan Tribal Gaming Authority
1 Am. Tribal Law 385 (Mohegan Gaming Disputes Trial Court, 1997)
Drysdale ex rel. Drysdale v. Mohegan Tribal Gaming Authority
4 Am. Tribal Law 562 (Mohegan Gaming Disputes Trial Court, 2003)
MacLean v. Office of the Director of Regulation
5 Am. Tribal Law 273 (Mohegan Gaming Disputes Court of Appeals, 2004)
Alday v. Mohegan Tribal Gaming Authority
6 Am. Tribal Law 476 (Mohegan Gaming Disputes Court of Appeals, 2005)
Miller v. Mohegan Tribal Gaming Authority
6 Am. Tribal Law 487 (Mohegan Gaming Disputes Court of Appeals, 2006)
Lubrano v. Brennan Beer Gorman Architects, LLP
7 Am. Tribal Law 369 (Mohegan Gaming Disputes Court of Appeals, 2008)
Lopez v. Mohegan Tribal Gaming Authority
9 Am. Tribal Law 170 (Mohegan Gaming Disputes Trial Court, 2010)

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Bluebook (online)
11 Am. Tribal Law 344, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kim-chai-mock-v-mohegan-tribal-gaming-authority-mohegangct-2013.