The case involved Barbara Izzarelli's product liability claims against R.J. Reynolds Tobacco Company, alleging that the design of Salem King menthol cigarettes—with heightened addictive properties and higher carcinogen levels than necessary—caused her larynx cancer after 25 years of smoking. A jury found R.J. Reynolds 58% responsible under strict liability and negligent design theories, attributing 42% responsibility to Izzarelli herself. R.J. Reynolds moved for judgment as a matter of law and a new trial, arguing insufficient evidence of a unique defect, improper exclusion of risk factor testimony, erroneous admission of youth marketing evidence, and flawed jury instructions on Connecticut product liability law and punitive damages. The court denied the motions, holding that the trial evidence supported the verdict by showing the cigarettes were uniquely designed in ways that distinguished them from other tobacco products and that the challenged rulings and instructions were proper.
The case involved a dispute over a performance surety bond issued by National Fire Insurance Company of Hartford for a condominium construction project contracted between Stonington Water Street Assoc., LLC and Hodess Building Co. After Hodess defaulted, Stonington sought to claim under the bond, but National Fire denied coverage due to alleged noncompliance with the bond's terms. Stonington then sued National Fire for breach of the bond, bad faith, and violations of Connecticut unfair practices statutes. The court granted National Fire's motion for summary judgment, holding that Stonington had failed to strictly comply with multiple conditions precedent in the bond and construction contract, which prejudiced the surety and discharged its obligations under Connecticut and Second Circuit law requiring strict compliance with surety bond terms.
The case involved plaintiff Barbara Izzarelli, who sued defendant R.J. Reynolds Tobacco Co. for larynx cancer allegedly caused by her long-term smoking of Salem King cigarettes, resulting in a 2010 jury verdict awarding her over $11 million in compensatory and punitive damages under strict liability and negligent design theories. Years earlier, in 2001, Izzarelli had filed a sealed offer of judgment for $400,000 under Conn. Gen. Stat. § 52-192a, which the defendant received but did not accept. The court granted Izzarelli's motion for offer-of-judgment interest, rejecting the defendant's objections that no separate "notice of filing" document had been served and that the award would violate due process. The core reasoning was that the statute requires only filing the offer with the court and providing notice of the offer to the defendant (which occurred contemporaneously), with no requirement for an additional titled notice document, and that the statutory sequence for triggering interest had been followed since the final judgment exceeded the offer amount.
This case involves a dispute between ACSTAR Insurance Company, as reinsurer and administrator for United Coastal Insurance Company, and its insured, Clean Harbors, Inc., over whether ACSTAR must defend and indemnify Clean Harbors in a separate lawsuit brought by McDonnell Douglas and Boeing for costs related to a 1991 fuel spill at a New Jersey site. Clean Harbors had subcontracted drilling work that caused the spill, later settled its claims against the subcontractor Trinity for $38,000 and released Trinity from liability without notifying United Coastal until years later, and ACSTAR argued that this release breached the policy's subrogation clause and prejudiced its rights. The court granted partial summary judgment to Clean Harbors and denied it to ACSTAR, holding that Clean Harbors did not breach the subrogation clause. The core reasoning was that the USF&G policy insuring Trinity contained a pollution exclusion that would have barred coverage for Trinity's drilling operations to test for pollutants, so ACSTAR had no viable subrogation rights that could have been impaired by the settlement.
The case involved Barbara Izzarelli, who developed larynx cancer after smoking Salem King cigarettes for over 25 years and sued manufacturer R.J. Reynolds Tobacco Co. for strict liability and negligent design. A jury awarded her over $7.9 million in compensatory damages (after reduction for 42% comparative responsibility) and found that punitive damages were warranted due to reckless disregard for user safety. Under Connecticut's Product Liability Act, the court was tasked with setting the amount of punitive damages, which cannot exceed twice the plaintiff's actual damages, while analyzing whether the traditional common-law limit to litigation costs (less taxable costs) still applies in statutory product liability actions. The court's reasoning centered on following Connecticut state law in this diversity case, reviewing the statute's text and history, and determining the appropriate punitive award within the statutory cap.
This case involves constitutional and tort claims by individuals subjected to an early-morning immigration raid in New Haven in 2007, who sued ICE officers, supervisors, and the United States for alleged Fourth and Fifth Amendment violations as well as state-law claims such as negligent hiring, training, and supervision. The court granted in part and denied in part the motions to dismiss: it dismissed claims for declaratory relief, negligent hiring, Fourth Amendment claims against certain defendants, and Fifth Amendment substantive and procedural due process claims, while denying dismissal of Fourth Amendment claims against some supervisors and equal protection claims, and allowing further discovery on negligent training and supervision. The core reasoning was that the FTCA provides only money damages and bars declaratory relief, some claims lacked sufficient factual allegations while others plausibly showed supervisory notice or discriminatory motive, the case was not barred by immigration statutes or Heck v. Humphrey, and a Bivens remedy was not precluded by the immigration scheme.