Ligeri v. White Road Capital, LLC, Series 168814

CourtConnecticut Appellate Court
DecidedMarch 10, 2026
DocketAC48077
StatusPublished

This text of Ligeri v. White Road Capital, LLC, Series 168814 (Ligeri v. White Road Capital, LLC, Series 168814) is published on Counsel Stack Legal Research, covering Connecticut Appellate Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ligeri v. White Road Capital, LLC, Series 168814, (Colo. Ct. App. 2026).

Opinion

************************************************ The “officially released” date that appears near the beginning of an opinion is the date the opinion will be published in the Connecticut Law Journal or the date it is released as a slip opinion. The operative date for the beginning of all time periods for the filing of postopinion motions and petitions for certification is the “officially released” date appearing in the opinion. All opinions are subject to modification and technical correction prior to official publication in the Connecti- cut Law Journal and subsequently in the Connecticut Reports or Connecticut Appellate Reports. In the event of discrepancies between the advance release version of an opinion and the version appearing in the Connecticut Law Journal and subsequently in the Connecticut Reports or Connecticut Appellate Reports, the latest version is to be considered authoritative. The syllabus and procedural history accompanying an opinion that appear in the Connecticut Law Journal and subsequently in the Connecticut Reports or Connecticut Appellate Reports are copyrighted by the Secretary of the State, State of Connecticut, and may not be reproduced or distributed without the express written permission of the Commission on Official Legal Publications, Judicial Branch, State of Connecticut. ************************************************ Ligeri v. White Road Capital, LLC, Series 168814

BENJAMIN LIGERI v. WHITE ROAD CAPITAL, LLC, SERIES 168814 ET AL. (AC 48077) Elgo, Clark and Westbrook, Js.

Syllabus

The plaintiff appealed from the trial court’s judgment granting, on standing grounds, motions to dismiss filed by the defendants. He claimed, inter alia, that the court improperly concluded that he lacked standing to prosecute the underyling action because he was not a party to the contracts that formed the basis of the action. Held:

The trial court did not abuse its discretion in denying the plaintiff’s request for an evidentiary hearing in accordance with Standard Tallow Corp. v. Jowdy (190 Conn. 48), as the plaintiff never claimed before the court that any disputed issues of fact needed to be resolved with respect to whether he was a proper party to invoke judicial resolution of the disputes alleged in the complaint.

The trial court properly dismissed the action as to all defendants with respect to the count of the plaintiff’s complaint seeking a declaratory judgment, as the plaintiff failed to demonstrate that he was the proper party to request the declaratory relief sought because that request arose entirely out of contracts between a nonparty, C Co., and the defendants, the plaintiff was not a party to those contracts, and, although, he was an individual guarantor of C Co.’s performance obligations, that status was not sufficient to confer standing on the plaintiff in his individual capacity.

The trial court improperly dismissed three counts of the plaintiff’s complaint directed against the defendant A Co. that sound in tortious interference with business expectancies, negligent misrepresentation, and a violation of the Connecticut Unfair Trade Practices Act (§ 42-110a et seq.), as the allegations made in support of those counts, namely, that A Co.’s unauthorized or illegal actions resulted in the freezing of the plaintiff’s personal PayPal account, demonstrated that he arguably had some direct and personal interest in those causes of action.

Argued September 15, 2025—officially released March 10, 2026

Procedural History

Action seeking, inter alia, a declaratory judgment as to the rights and remedies of parties to certain accounts receivable factoring agreements, and for other relief, brought to the Superior Court in the judicial district of New London, where the court, Spallone, J., denied the plaintiff’s motion for an evidentiary hearing; thereafter, Ligeri v. White Road Capital, LLC, Series 168814

the court, Spallone, J., granted the defendants’ motions to dismiss and rendered judgment thereon, from which the plaintiff appealed to this court. Reversed in part; further proceedings. Edward E. Bona, for the appellant (plaintiff). Jared M. Alfin, with whom, on the brief, was Forrest A. Noirot, for the appellee (named defendant). Gary J. Greene, with whom, on the brief, was Christo- pher Ryan Boy, for the appellee (defendant The Fund- works, LLC).

Opinion

WESTBROOK, J. The plaintiff, Benjamin Ligeri, appeals from the judgment of the trial court granting, on standing grounds, motions to dismiss filed by the defendants, White Road Capital, LLC, Series 168814, doing business as GFE Holdings (White Road); The Fund- works, LLC (Fundworks); and Advance Servicing, Inc. (Advance).1 On appeal, the plaintiff claims that the court improperly (1) granted the defendants’ motions to dis- miss without first conducting an evidentiary hearing in accordance with Standard Tallow Corp. v. Jowdy, 190 Conn. 48, 56, 459 A.2d 503 (1983), and (2) concluded that the plaintiff lacked standing to prosecute the underlying action because he was not a party to the contracts that formed the basis of the action. We agree with the plain- tiff that the court improperly dismissed the action with respect to counts two, three and four of the complaint directed solely against Advance and remand for further proceedings on those counts; we otherwise affirm the judgment of the trial court.2 The following procedural history and facts, as alleged in the operative complaint or necessarily implied by 1 Advance did not file a brief with this court or otherwise participate in the present appeal. 2 The plaintiff also raises as a third claim that the court improperly determined that it lacked subject matter jurisdiction to render the declar- atory judgment sought by the plaintiff in count one of the complaint. Ligeri v. White Road Capital, LLC, Series 168814

those allegations, are relevant to this appeal. See May v. Coffey, 291 Conn. 106, 108, 967 A.2d 495 (2009). The plaintiff is a resident of Voluntown and the owner and principal of Central Concepts, Inc. (Central), a Rhode Island corporation. Central is a third-party logistics pro- vider for Amazon, Inc. (Amazon), and relies on Amazon for its revenue. In his capacity as principal for Central, the plaintiff executed certain “accounts receivables fac- toring contracts” (contracts) with each of the defen- dants, all nonresident business entities.3 Pursuant to the contracts, the defendants agreed to make up-front payments to Central in exchange for Central’s future receivables from Amazon.4 The plaintiff, in his individual capacity, also executed personal guaranties of Central’s contractual obligations. The plaintiff commenced the underlying action in August, 2023. The operative amended complaint con- tains four counts. Count one is directed at all three of the defendants and seeks a declaratory judgment. Spe- cifically, the plaintiff asked the court to declare that no sums are due from Central to the defendants under the parties’ contracts, and that no executions of any judg- ments obtained against Central may issue in Connecticut unless and until Central receives funds that it claims Given our conclusion that the plaintiff lacked standing with respect to count one, it is unnecessary for us to address that claim. 3 White Road is a New York limited liability company, Fundworks is a California limited liability company, and Advance is a company incorporated in New Jersey. 4 The complaint is not a model of clarity with respect to the precise nature of the business relationships between the various parties.

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Ligeri v. White Road Capital, LLC, Series 168814, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ligeri-v-white-road-capital-llc-series-168814-connappct-2026.