Novicki v. City of New Haven

709 A.2d 2, 47 Conn. App. 734, 1998 Conn. App. LEXIS 71
CourtConnecticut Appellate Court
DecidedFebruary 24, 1998
DocketAC 16464
StatusPublished
Cited by71 cases

This text of 709 A.2d 2 (Novicki v. City of New Haven) 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
Novicki v. City of New Haven, 709 A.2d 2, 47 Conn. App. 734, 1998 Conn. App. LEXIS 71 (Colo. Ct. App. 1998).

Opinion

Opinion

DUPONT, J.

The plaintiff appeals from the judgment rendered by the trial court granting the defendant city of New Haven’s motion to dismiss a personal injury suit brought pursuant to General Statutes § 13a-149. The plaintiff claims that the trial court improperly (1) granted the defendant’s motion to dismiss for lack of subject matter jurisdiction and (2) sustained the defendant’s objection to the plaintiffs request for leave to amend her complaint. We affirm the judgment of the trial court.

The plaintiff alleged in her complaint filed in October, 1991, that on October 19, 1990, she had suffered injuries as a result of a fall on a walkway that runs from Davis Street to the north exit of the Davis Street School in New Haven, and attached to her complaint the notice of this incident dated December 13, 1990, which she had sent to the city, as required by § 13a-149. The complaint also alleged that the city had a duty to keep and maintain the sidewalks and streets within its territorial limits in a reasonably safe condition, but did not allege that the city had such a duty with regard to the particular walkway that is the subject of the plaintiffs complaint.

The defect alleged in the plaintiffs statutory notice of claim, and in her complaint, was described as a large, indented crack at the top of a street ramp adjacent to the stairway of a walkway leading to the Davis Street School. The exact location of the crack was given.1 The [736]*736complaint alleged various ways in which the city had breached its alleged statutory duties to the plaintiff. On April 13, 1993, the plaintiff amended her complaint to add a claim that the city was also in breach of its statutory duty because the ramp was too steep.2

On August 11, 1995, the city moved for summary judgment claiming that the property on which the plaintiff allegedly fell, although owned by the city, was not a city “highway” under the highway defect statute. General Statutes § 13a-149.3 The city also claimed that it was not the proper defendant in the action. The city’s motion for summary judgment, filed prior to its motion to dismiss, was denied on January 29, 1996, because the court could not conclude, as a matter of law, that the location of the plaintiffs fall was not a public highway or sidewalk. The court also noted in its denial of summary judgment, the absence of any affidavit establishing what party had actual control over the location of the plaintiffs fall.

On or about March 22, 1996, the plaintiff moved to amend her complaint a second time to add a claim of [737]*737nuisance. The city objected to the amendment, which objection was initially overruled. On July 2, 1996, the city moved to reargue its objection on two grounds: (1) that the claim was barred by the statute of limitations, and (2) that the original highway defect cause of action failed to put the city on notice of a nuisance claim for purposes of the city’s investigation, leaving the city unequipped to defend such a claim more than five years later. On July 11, 1996, the city’s motion to reargue was granted, limited to the second ground. On September 24, 1996, the court, Corradino, J., heard reargument and sustained the defendant’s objection.

On April 4, 1996, the city moved to dismiss the complaint for lack of subject matter jurisdiction, claiming that the plaintiff could not bring herself within the statutory exception to governmental immunity set forth in § 13a-149 because the walkway was not a road for purposes of that statute, and because the city was not the party bound to maintain or repair the walkway. The city attached affidavits stating that the walkway was on the property of the Davis Street School, and that the New Haven board of education, not the city, was the party bound to maintain that property.

On September 25, 1996, the court, Gray, J., heard oral argument on the city’s motion to dismiss for lack of subject matter jurisdiction and granted the motion. The city asserted that absent compliance with the requirements of § 13a-149, the doctrine of sovereign immunity deprived the court of subject matter jurisdiction. The city further asserted that the statutory requirements for the state’s legislative waiver of immunity, set forth in § 13a-149, had not been met because the plaintiffs complaint failed to allege, nor could it be established, that (1) the area of the plaintiffs alleged [738]*738fall was on a “road or bridge,” or (2) the city was the party bound to keep the area in repair. The city also filed two supporting affidavits as evidence that it was not the party responsible for the maintenance and repair of the walkway at issue.4 The plaintiff relied on a previously filed affidavit stating that the city was the owner of record of the Davis Street School property.5 The trial court agreed that the requirements of § 13a-149 had not been met and, accordingly, granted the city’s motion to dismiss. The plaintiff had also filed a motion to reargue the city’s objection to the plaintiffs request to amend the complaint as to the September 24, 1996 ruling, but the motion was rendered moot by the dismissal of the action.

The plaintiff first claims that the trial court improperly granted the city’s motion to dismiss for lack of subject matter jurisdiction. It is well established that the state or a city is immune from suit unless it consents to be sued by appropriate legislation waiving sovereign immunity in certain prescribed cases. Baker v. Ives, 162 Conn. 295, 298, 294 A.2d 290 (1972). Thus, in a case where a government is the defendant, courts do not have subject matter jurisdiction unless such jurisdiction [739]*739is statutorily conferred. The legislature, however, has carved out certain statutory exceptions to the general rule of sovereign immunity and allowed governmental entities to be sued under certain limited circumstances. Berger, Lehman Associates, Inc. v. State, 178 Conn. 352, 356, 422 A.2d 268 (1979) (sovereign immunity can be waived by appropriate legislative action); State v. Chapman, 176 Conn. 362, 364, 407 A.2d 987 (1978) (same). The highway defect statute, § 13a-149, on which the plaintiff depends for her cause of action, is one of those exceptions.

Where a court’s jurisdiction arises solely from a statutory waiver of sovereign immunity, the statutory provisions must be strictly construed. Duguay v. Hopkins, 191 Conn. 222, 232, 464 A.2d 45 (1983); Spring v. Constantino, 168 Conn. 563, 570, 362 A.2d 871 (1975). Accordingly, where a statute or court rule sets prerequisites to suit by a particular plaintiff, a plaintiff not meeting the statutory criteria lacks standing and the court is said to lack jurisdiction over the case. Mystic Marinelife Aquarium, Inc. v. Gill, 175 Conn. 483, 492-93, 400 A.2d 726 (1978).

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Giannoni v. Commissioner of Transportation
141 A.3d 784 (Supreme Court of Connecticut, 2016)
Pramuka v. Cromwell
Connecticut Appellate Court, 2015
Escourse v. 100 Taylor Avenue, LLC
Connecticut Appellate Court, 2014
Cuozzo v. Town of Orange
82 A.3d 647 (Connecticut Appellate Court, 2013)
Stroud v. Mid-Town Tire & Supply, Inc.
81 A.3d 243 (Connecticut Appellate Court, 2013)
Ortiz v. Metropolitan District
56 A.3d 952 (Connecticut Appellate Court, 2012)
Bartlett v. Metropolitan District Commission
7 A.3d 414 (Connecticut Appellate Court, 2010)
Himmelstein v. Town of Windsor
974 A.2d 820 (Connecticut Appellate Court, 2009)
Read v. Town of Plymouth
955 A.2d 1255 (Connecticut Appellate Court, 2008)
Bellman v. Town of West Hartford
900 A.2d 82 (Connecticut Appellate Court, 2006)
Kozlowski v. Commissioner of Transportation
876 A.2d 1148 (Supreme Court of Connecticut, 2005)
Integlia v. Mohegan Tribal Gaming Authority
6 Am. Tribal Law 527 (Mohegan Gaming Disputes Trial Court, 2005)
In re Pro Hac Vice Admission of Reich
851 A.2d 308 (Connecticut Appellate Court, 2004)
McGrath v. New Milford, No. Cv 02 0088644s (Mar. 26, 2003)
2003 Conn. Super. Ct. 3968 (Connecticut Superior Court, 2003)
Canzanella v. East Haven, No. Cv98-0412895 (Dec. 19, 2002)
2002 Conn. Super. Ct. 16200 (Connecticut Superior Court, 2002)
Rivera v. City of Meriden
806 A.2d 585 (Connecticut Appellate Court, 2002)
Simpson v. Southern New England Telephone Co., No. 558798 (Jul. 26, 2002)
2002 Conn. Super. Ct. 9544 (Connecticut Superior Court, 2002)
Guerrieri v. Hanson, No. Cv01 038 06 32 (May 10, 2002)
2002 Conn. Super. Ct. 6115 (Connecticut Superior Court, 2002)
Nelson v. City of Bristol, No. Cv01-0508846 (Mar. 27, 2002)
2002 Conn. Super. Ct. 3800 (Connecticut Superior Court, 2002)
Hodge v. Town of Old Saybrook, No. Cv 99-0088746 (Dec. 20, 2001)
2001 Conn. Super. Ct. 16862 (Connecticut Superior Court, 2001)

Cite This Page — Counsel Stack

Bluebook (online)
709 A.2d 2, 47 Conn. App. 734, 1998 Conn. App. LEXIS 71, Counsel Stack Legal Research, https://law.counselstack.com/opinion/novicki-v-city-of-new-haven-connappct-1998.