Pittu v. Bugaj Contractors Co., LLC

234 Conn. App. 28
CourtConnecticut Appellate Court
DecidedJuly 29, 2025
DocketAC47215
StatusPublished

This text of 234 Conn. App. 28 (Pittu v. Bugaj Contractors Co., LLC) 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
Pittu v. Bugaj Contractors Co., LLC, 234 Conn. App. 28 (Colo. Ct. App. 2025).

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 postopin- ion motions and petitions for certification is the “offi- cially 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 Connecti- cut 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 Jour- nal 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. ************************************************ Page 0 CONNECTICUT LAW JOURNAL 0, 0

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SARAH PITTU ET AL. v. BUGAJ CONTRACTORS COMPANY, LLC (AC 47215) Moll, Suarez and Seeley, Js.

Syllabus

The defendant contractor appealed from the judgment of the trial court discharging a mechanic’s lien that the defendant had placed on certain real property owned by the plaintiffs. The defendant claimed that the court improperly shifted the burden of proof to the defendant by requiring it to prove that it did not breach a contract entered into between the parties, rather than requiring it to prove only that there was probable cause to sustain its lien. Held:

This court concluded that, although the trial court articulated the correct burdens of proof delineated in the statute (§ 49-35b) governing the hearing on the plaintiffs’ application for the discharge of the mechanic’s lien, the trial court’s determinations rested on legally erroneous grounds, as the trial court incorrectly determined that its finding that the defendant had breached the parties’ contract precluded the defendant from establishing a valid mechanic’s lien, because, even though the defendant had not substantially performed under the parties’ contract, the defendant could properly rely on the contract price, and the invoices and change orders submitted there- with, to demonstrate the value of its materials and services for the purposes of establishing that there was probable cause to sustain the lien.

Argued January 13—officially released July 29, 2025

Procedural History

Application to reduce or discharge a mechanic’s lien on certain real property owned by the plaintiffs, brought to the Superior Court in the judicial district of Fairfield and tried to the court, Hon. Barry K. Stevens, judge trial referee; judgment granting the application, from which the defendant appealed to this court. Reversed; further proceedings.

Sabato P. Fiano, for the appellant (defendant). Anthony J. Musto, for the appellees (plaintiffs). 0, 0 CONNECTICUT LAW JOURNAL Page 1

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Opinion

SUAREZ, J. The defendant, Bugaj Contractors Com- pany, LLC, appeals from the judgment of the trial court discharging a mechanic’s lien that it had placed on certain real property owned by the plaintiffs, Sarah Pittu and Raul Herrera. The defendant claims that the court improperly (1) shifted the burden of proof to the defen- dant at the hearing held pursuant to General Statutes § 49-35a on the plaintiffs’ application to discharge the mechanic’s lien by requiring it to prove that it did not breach a contract entered into between the parties, rather than requiring it to prove only that there was probable cause to sustain its lien, (2) found, ‘‘presum- ably by clear and convincing evidence,’’ that the defen- dant breached the contract between the parties, and (3) concluded that the mechanic’s lien was premised entirely on the contract and, therefore, failed to sustain the lien on the basis of applicable principles of restitu- tion and/or unjust enrichment.1 (Emphasis omitted.) In support of its first claim, the defendant argues that it was not obligated to prove a breach of contract claim at the hearing. We agree that the trial court incorrectly determined that its finding that the defendant breached the parties’ contract precluded the defendant from establishing a valid mechanic’s lien and, accordingly, we reverse the judgment of the court and remand the case for further proceedings. The following facts, as found by the court or as undis- puted in the record, and procedural history are relevant to this appeal. ‘‘In a contract dated December 23, 2020, the plaintiffs retained the defendant to perform home improvement renovations [(project)] on [their] property [located at 222 High Ridge Road in Fairfield (property)]. Pursuant to the contract, the total cost of the project 1 For ease of discussion, we address the claims in a different order than they were presented in the defendant’s principal appellate brief. Page 2 CONNECTICUT LAW JOURNAL 0, 0

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was $662,050 (plus any approved change orders). The evidence indicates that the plaintiffs paid $502,961.41 to the defendant and another $9843.35 to third parties for work under the contract or relating to it.2 . . . ‘‘The work was scheduled to begin on January 4, 2021, and was to be substantially completed by August 15, 2021. The contract provide[s] that time was not of the essence. The contract further provide[s] that a [t]empo- rary certificate of occupancy shall be deemed substan- tial completion.’’ (Citations omitted; footnote added; internal quotation marks omitted.) The project was not substantially completed by August 15, 2021, or by the last time the defendant worked at the property near the end of June, 2022. No temporary certificate of occu- pancy had been obtained by the time the defendant stopped work at the property. In September, 2022, the defendant filed a mechanic’s lien on the property, which indicated that its filing was ‘‘in accordance with a certain contract between it and the [plaintiffs]’’ and was ‘‘for just services rendered and/ or materials furnished’’ during the project. The plaintiffs subsequently filed an application to reduce or discharge the mechanic’s lien, alleging that there was no probable cause to sustain the validity of the lien and/or that the amount of the lien was excessive. The defendant filed an objection thereto. On May 19 and June 30, 2023, the court, Hon. Barry K. Stevens, judge trial referee, held a hearing on the plaintiffs’ application. Over the course of this hearing, the court received documentary evidence, which included 2 At the court’s request, the parties filed a stipulation summarizing the amount that the defendant claimed it was owed, which totaled $237,407.24, and the plaintiffs’ position as to the maximum possible lien amount, which totaled $144,805.24. Specifically, the plaintiffs disputed three invoices for ‘‘[e]xtras [c]laimed’’ by the defendant. The stipulation indicated that its filing did not constitute an admission by the plaintiffs that any amount was due. 0, 0 CONNECTICUT LAW JOURNAL Page 3

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Bluebook (online)
234 Conn. App. 28, Counsel Stack Legal Research, https://law.counselstack.com/opinion/pittu-v-bugaj-contractors-co-llc-connappct-2025.