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Expressway Associates II v. Friendly Ice Cream Corp.

Citations: 218 Conn. 474; 590 A.2d 431; 1991 Conn. LEXIS 233Docket: 14090

Court: Supreme Court of Connecticut; May 7, 1991; Connecticut; State Supreme Court

Narrative Opinion Summary

In a dispute between Expressway Associates II and Friendly Ice Cream Corporation, the former sought injunctive relief and damages for interference with a claimed right-of-way. The trial court initially ruled against Expressway, finding that notice to Friendly was required prior to construction, which had not been given due to lack of permits. The Appellate Court reversed this decision, clarifying that notice was only necessary for future permanent construction, thereby recognizing Expressway's existing right-of-way and granting injunctive relief. However, the issue of damages remained contentious. Despite the Appellate Court's directive for further proceedings on damages, the higher court found that Expressway failed to prove actual damages, supported by its counsel's concession of entitlement to only nominal damages. The court highlighted that damages must be established with reasonable certainty, and in absence thereof, Expressway was only entitled to $1 in nominal damages. Consequently, the decision for further damages proceedings was overturned, affirming the nominal damages award, with concurrence from all justices.

Legal Issues Addressed

Admissibility of Attorney Admissions

Application: The court accepted the attorney's admissions regarding the lack of actual damages as binding against Expressway.

Reasoning: Admissions made by the attorney are generally admissible against the client, and in this case, the evidence supported counsel’s statement.

Burden of Proof for Damages

Application: Expressway failed to demonstrate actual damages at trial, and the court emphasized the necessity of proving damages with reasonable certainty.

Reasoning: It was emphasized that the burden of proving damages lies with the claimant, and damages must be established with reasonable certainty, as they are essential to the plaintiff's proof.

Nominal Damages

Application: The court concluded that Expressway was entitled to nominal damages due to its failure to prove actual damages, affirming a judgment of $1.

Reasoning: Although Expressway proved interference with its right-of-way, it only substantiated a claim for nominal damages, which entitles a plaintiff to at least $1 despite the absence of actual damages.

Right-of-Way and Notice Requirements

Application: The Appellate Court clarified that Expressway's right-of-way was not contingent on notice for non-permanent roadway use, thus reversing the trial court's interpretation.

Reasoning: The Appellate Court found that the trial court misinterpreted the documents governing the right-of-way. It clarified that notice was only required for future construction of a permanent roadway and that Expressway had a present right-of-way.