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Hallas v. Town of Windsor
Citations: 217 Conn. 689; 587 A.2d 149; 1991 Conn. LEXIS 73Docket: 14007
Court: Supreme Court of Connecticut; March 12, 1991; Connecticut; State Supreme Court
The key issue in this appeal revolves around whether a judgment that declared moot the counts of a complaint seeking injunctive relief also rendered moot a separate count seeking damages. In a prior case, Hallas v. Windsor, the court determined that the plaintiffs' claims for injunctive relief concerning town appropriations had become moot due to a subsequent town meeting that ratified those appropriations. The court concluded that the trial court lacked jurisdiction to issue a declaratory judgment regarding the appropriations. Upon remand, the plaintiffs sought damages based on alleged violations of constitutional rights and claims of fraud. However, the trial court ruled that the earlier decision deprived it of jurisdiction to hear the damages claim. The plaintiffs appealed this dismissal, but the Appellate Court upheld the dismissal based on mootness. The Supreme Court granted certification to review whether the Appellate Court's dismissal was appropriate. The Supreme Court determined that the plaintiffs' damages claim was not moot, clarifying that while injunctive relief claims may become moot if the allegedly unconstitutional activity ceases, this does not apply to damages claims arising from that activity prior to its cessation. The court referenced a similar case, Moshier v. Goodnow, where it held that while an injunction may be dissolved due to subsequent lawful actions, the damages claim remained viable, thereby establishing that a sufficient controversy existed to avoid mootness. The court's decision in Hallas I addressed only the viability of two counts in the plaintiffs' complaint that sought injunctive relief, which were deemed moot due to the ratification by the town meeting. The court determined that the controversy regarding the lack of a town meeting vote ceased to exist after the special town meeting where the contested appropriations were approved. Consequently, the court found it lacked jurisdiction to evaluate the merits of the injunctive relief claims and refrained from commenting on the implications of the ratification for actions prior to the vote or whether ratification was necessary. The court clarified that the mootness finding pertained solely to the injunctive relief counts, leaving the third count, which claimed damages, unresolved. The Appellate Court improperly dismissed the plaintiffs' appeal regarding the third count, leading to the reversal of its judgment. The case is remanded to the Appellate Court with instructions to return it to the trial court to set aside the dismissal and proceed accordingly. The defendants include the town of Windsor and its finance officials.