SC20285 - Garcia v. Cohen ("In this negligence action, a jury returned a verdict finding the defendants, Robert Cohen and Diane Cohen, not liable as landlords for injuries the plaintiff, Ussbasy Garcia, suffered when she slipped and fell on the staircase outside of her apartment building. The plaintiff appealed to the Appellate Court, claiming that the trial court improperly rejected her request to charge and to instruct the jury that, the defendants, as the possessors of real property, had a nondelegable duty to maintain the premises. Garcia v. Cohen, 188 Conn. App. 380, 381–82, 204 A.3d 1245 (2019). The Appellate Court declined to review the plaintiff's claim, concluding that the general verdict rule applied because the plaintiff had failed to object when the trial court denied her request to submit her proposed interrogatories to the jury. Id., 386. Additionally, the Appellate Court concluded that the plaintiff should have made, but failed to do so, an independent claim of error on appeal on the basis of the trial court's denial of her request to submit her proposed interrogatories to the jury. Id., 386–87.

We disagree with the Appellate Court's conclusion that the general verdict rule bars appellate review of the plaintiff's jury instruction claim. The general verdict rule does not apply in the present case because the plaintiff had requested that the trial court submit her properly framed interrogatories to the jury and had objected when it denied her request. She properly framed her interrogatories by submitting questions addressing her claim of negligence and the defendants' denial of negligence and special defense of contributory negligence. The claims of negligence and contributory negligence are so intertwined with the plaintiff's nondelegable duty jury charge claim on appeal that the general verdict rule does not bar review. Additionally, the plaintiff was not required on appeal to assert an independent claim of error on the basis of the trial court's rejection of her request to submit the interrogatories to the jury. Rather, the plaintiff's submission of interrogatories and her objection upon the court's refusal to submit them to the jury is a defense to application of the general verdict rule, not an independent claim of error. For these reasons, we reverse the judgment of the Appellate Court and remand the case to that court to undertake a review of the trial court's denial of the plaintiff's request for a jury instruction on the nondelegable duty doctrine.")

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AC41989 - Jolley v. Vinton ("The self-represented plaintiff, Carlton Jolley, appeals from the judgment rendered in favor of the defendant, Captain Brian Vinton, a former administrative captain at the Enfield Correctional Institution (Enfield), in this action brought pursuant to 42 U.S.C. § 1983, alleging that the defendant retaliated against the plaintiff for providing legal advice to his fellow inmates while incarcerated at Enfield.Because we conclude that the trial court's finding that the plaintiff failed to prove a causal connection between his conduct and the alleged retaliation was not clearly erroneous, we affirm the judgment of the trial court.")

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SC20122 - Rutter v. Janis (Negligence; "Subject to certain requirements, General Statutes § 14-60 (a) permits motor vehicle dealers to temporarily loan a dealer license plate to, inter alia, the purchaser of one of their vehicles while that purchaser's registration is pending, but "for not more than thirty days in any year . . . ." The dispositive issue in this certified appeal is whether, for purposes of calculating that thirty day period, the "first day" is the date on which the dealer loans the plate to the purchaser or the first full calendar day thereafter.

Following a fatal motor vehicle accident, the plaintiffs in this joint appeal, Casey Leigh Rutter, Nancy Beale, as administratrix of the estate of Lindsey Beale, and Jason Ferreira, each commenced an action against the defendant Danbury Fair Hyundai, LLC, a motor vehicle dealer whose dealer license plate was displayed on one of the vehicles involved in the accident. The trial court concluded that the accident occurred on the last day of the thirty day limitation period of § 14-60 (a) because the day during which the defendant loaned the plate was not included in the calculation of the thirty day period. The Appellate Court agreed and affirmed the judgments of the trial court; see Rutter v. Janis, 180 Conn. App. 1, 5, 182 A.3d 85 (2018); and we granted certification, limited to the issue of whether the Appellate Court correctly excluded the date of the loan when calculating the thirty day loan period. See Rutter v. Janis, 329 Conn. 904, 185 A.3d 594 (2018).

We agree with the Appellate Court that the day of the loan does not count toward the thirty day limitation period of § 14-60 (a). In particular, we conclude that the legislature's unqualified use of the term "days"—a term that has a well established legal meaning in our jurisprudence—indicates that it intended the thirty day period to be measured in terms of full calendar days. Therefore, because the day of the loan was a "fraction" of a day rather than a full calendar day, it must be excluded. This construction is consistent with this court's long recognized policy that, when calculating statutory and other deadlines, "the day of the act from which a future time is to be ascertained . . . is to be excluded from the calculation . . . ." Weeks v. Hull, 19 Conn. 376, 382 (1849). This court established, and has consistently adhered to, this rule as a matter of policy in order to ensure uniformity and predictability in the computation of deadlines, and we see no reason why it should not be applied to § 14-60 (a). Accordingly, we affirm the judgment of the Appellate Court.")

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SC20243 - Graham v. Friedlander (Negligent hiring; "The plaintiffs, the parents of four school-age children, individually and on behalf of their children, brought this action against the Board of Education of the City of Norwalk (board) and three of its members, in their official capacities (board defendants), the city of Norwalk (city), and Spectrum Kids, LLC, and its owner . . . On appeal, we are asked to determine whether the claims alleged in the plaintiffs' complaint seek relief for a failure to provide special education services under the Individuals with Disabilities Education Act (act), 20 U.S.C. § 1400 et seq., thus triggering an administrative exhaustion requirement contained in that act and within General Statutes § 10-76h, or whether the plaintiffs' action seeks relief for something other than the provision of a free appropriate public education (FAPE), thereby relieving the plaintiffs of the exhaustion requirement. To decide this issue at this stage in the litigation—on review of the trial court's decision to grant the board defendants' motion to dismiss for lack of subject matter jurisdiction on the basis of a failure to exhaust administrative remedies—we must confine our inquiry to the allegations in the plaintiffs' complaint. On the basis of those allegations, we conclude that the plaintiffs seek relief for something other than the denial of a FAPE and were, therefore, not obligated to exhaust their administrative remedies. Accordingly, we agree with the plaintiffs that the trial court improperly dismissed their action on the ground that the plaintiffs had not exhausted their administrative remedies. As an alternative ground for upholding the granting of the motion to dismiss, the defendants ask us to determine that the board defendants acted as agents of the state in providing special education services, therefore entitling them to sovereign immunity. We agree with the trial court that the board defendants were acting under the control of, and as an agent of, the municipality rather than the state, and were not entitled to sovereign immunity. Accordingly, we uphold the trial court's denial of the board defendants' motion to dismiss on the sovereign immunity ground. . .

The judgment is reversed only as to the granting of the board defendants' motion to dismiss on the ground that the plaintiffs failed to exhaust their administrative remedies and the case is remanded with direction to deny the board defendants' motion to dismiss as to the exhaustion claim and for further proceedings according to law; the judgment is affirmed in all other respects.")

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AC42024 - Raczkowski v. McFarlane ("The plaintiff, Toni Raczkowski, brought the underlying negligence action against the defendant landlord, Evelyn Garrow. The plaintiff sought compensation for damages she allegedly sustained when she was bitten by a dog owned by the defendant's tenant, David J. McFarlane, on the leased property. The plaintiff appeals from the summary judgment rendered by the trial court in favor of the defendant. The plaintiff claims that the court improperly granted the defendant's motion for summary judgment because it erroneously concluded that the defendant did not owe her a duty of care on the basis of the lease agreement between the defendant and McFarlane.We disagree and, accordingly, affirm the judgment of the trial court.")

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