Nelson v. the Stop Shop Co., Inc., No. 307467 (May 7, 1992)
Opinion of the Court
On January 22, 1991, the defendant filed its answer and five special defenses. See Defendant's Answer and Special Defenses #116. The first four special defenses claim that the plaintiff's action fails to satisfy the requirements of General Statutes
On February 4, 1992, the plaintiff filed a motion to strike the defendant's five special defenses, contending that they are inadequate as a matter of law and that the first, second, third and fourth special defenses are redundant and superfluous. The defendant filed its memorandum in opposition on February 18, 1992, claiming that the special defenses raise factual issues which cannot be determined on a motion to strike, and further, that a request to revise is the proper method of challenging a redundant or superfluous pleading, not a motion to strike.
A motion to strike filed pursuant to Practice Book 152 challenges the legal sufficiency of a pleading. Mingachos v. CBS, Inc.,
The defendant pleads respectively in his first and fifth special defenses that the plaintiff's substituted complaint was not filed within the time limit mandated by General Statutes 52-59a(a) and the statute of limitations provided for in General Statutes
General Statutes
(a) If any action, commenced within the time limited by law, has failed . . . because of insufficient service or return of the writ due to unavoidable accident or the default or neglect of the officer to whom it was committed, . . . the plaintiff, . . . may commence a new action, . . . for the same cause at any time within one year after the determination of the original action or after the reversal of the judgment.
General Statutes
No action to recover damages for injury to the person, . . . caused by negligence, . . . shall be brought but within two years from the date when the injury is first sustained or discovered or in the exercise of reasonable care should have been discovered, and except that no such action may be brought more than three years from the date of the act or omission complained of, . . . .
General Statutes
The parties agree in their memoranda pertaining to this motion that the plaintiff was allegedly injured on July 1, 1988, and that the original complaint made returnable on July 17, 1990, was dismissed by the court on September 17, 1990 for insufficiency of service of process. See also Plaintiff's Substituted Complaint, paras. 1, 2. The defendant argues, however, that since the first action was dismissed for insufficiency of service of process, the plaintiff never "commenced" the first action within the meaning of General Statutes
The plain meaning of General Statutes
Although the term "commenced" generally means the date at which valid service upon the defendant is perfected, see General Statutes
In the present case, it is undisputed that the plaintiff initiated the original action by attempted, albeit insufficient, service upon the defendant on June 27, 1990. (See ruling in Nelson v. Stop Shop Co.,
In its second and third special defenses, the defendant pleads, respectively, that "the insufficient service was not due to unavoidable accident as required by the Accidental Failure of Suit Statute," and "the insufficient service was not due to the default or neglect of the officer to whom it was committed . . . [and] may not be maintained under the Accidental Failure of Suit Statute." The plaintiff seeks to strike these defenses, contending that General Statutes +/-
The two prior rulings referred to by the plaintiff do not address the issue presented in this motion. The first ruling, by the Appellate Court, merely affirmed the trial court's dismissal of the plaintiff's original action for insufficient services. See Nelson v. Stop Shop Cos., Inc.
When an action is brought pursuant to the accidental failure of suit statute on the basis of insufficient service, such insufficiency must be attributable to unavoidable accident or the default or neglect of the serving officer. "The Court must interpret the [s]tatute as written . . . and it is to be considered as a whole, with a views towards reconciling its separate parts in order to render a reasonable overall interpretation . . . ." Hayes v. Traveler's Indemnity Co.,
In its fourth special defense, the defendant pleads that the plaintiff's original action had not failed at the time the present suit was commenced, and thus, the "plaintiff has failed to satisfy the preconditions for bringing a claim under the accidental failure of suit statute." Defendant's Fourth Special Defense.
The issue raised by the defendant's fourth defense was submitted to this court in a motion to dismiss dated October 11, 1991. See Motion to Dismiss #105. In that motion, the defendant contended that the plaintiff's complaint was commenced before a final determination of the first action had been reached, and therefore, the court lacked subject matter jurisdiction. Id. The court held that the plaintiff had standing to pursue the present action under the accidental failure of suit statute, General Statutes
In the absence of any evidence that a prior ruling is clearly erroneous, the judge should treat that ruling as law of the case. Breen v. Phelps,
As a final matter, the plaintiff claims that the defendant's first, second, third and fourth special defenses are redundant and superfluous and should be stricken.
A motion to strike tests the legal sufficiency of a pleading. Practice Book 152. The proper method of raising issues concerning redundancy or superfluous pleadings is to file a request to revise pursuant to Practice Book 147(s). The plaintiff's motion is denied as to this ground.
The defendant's first, fourth and fifth special defenses are legally insufficient and are stricken. The defendant's second and third special defenses are legally sufficient and the plaintiff's motion are denied as to these defenses. Finally, the plaintiff's claim of redundancy is inappropriate and should have been addressed through a request to revise pursuant to Practice Book 147(2).
Thomas V. O'Keefe, Jr., Judge
Case-law data current through December 31, 2025. Source: CourtListener bulk data.