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Tighe v. Town of Berlin

Citations: 259 Conn. 83; 788 A.2d 40; 2002 Conn. LEXIS 11Docket: SC 16439

Court: Supreme Court of Connecticut; January 22, 2002; Connecticut; State Supreme Court

Narrative Opinion Summary

The case involves an appeal by property owners adjacent to a section of Stantack Road, which was abandoned by the town, challenging the denial of their request for an injunction to remove a gate obstructing access. The plaintiffs argued the gate caused irreparable harm by limiting access, contrary to their rights under General Statutes 13a-55, which they interpreted as preserving a public right of travel. The court affirmed the trial court's decision, emphasizing that the statute only grants private easement rights to abutting owners, not public travel rights. The defendant, a municipality, acted within its powers under General Statutes 7-148 to manage traffic and ensure safety by installing the gate. The court found no abuse of discretion in the trial court's decision, noting the gate's safety benefits outweighed the plaintiffs' inconvenience and did not constitute irreparable harm. The ruling underscores the principle that municipalities can regulate access to ensure public safety, even on abandoned roads, as long as private access rights are preserved. The appellate court's decision was affirmed, with only James and Joyce Tighe remaining as plaintiffs and the town of Berlin as the defendant, following procedural adjustments.

Legal Issues Addressed

Balance of Equities in Injunctions

Application: The court found that the safety benefits of the gate outweighed the inconvenience to the plaintiffs, justifying the denial of the injunction request.

Reasoning: The trial court evaluated the balance between residents' safety and the plaintiffs' access to their property. It determined that the inconvenience of unlocking a gate is minimal compared to the safety benefits it provides, and this does not constitute an undue obstruction of the plaintiffs' right-of-way.

Injunction Requirements and Discretion

Application: The trial court denied the plaintiffs' request for an injunction as they failed to demonstrate irreparable harm and the absence of an adequate legal remedy.

Reasoning: A party requesting an injunction must demonstrate irreparable harm and the absence of an adequate legal remedy. The trial court has discretion in granting or denying such requests, and its decisions are subject to review only for legal errors or abuse of discretion.

Interpretation of General Statutes 13a-55

Application: The court determined that General Statutes 13a-55 does not grant public right of travel over abandoned roads but confirms private access easements for abutting property owners.

Reasoning: The 1990 amendment to General Statutes 13a-55 clarifies that property owners can utilize a private right-of-way along an abandoned road for utility services, without reviving public access to such a road post-abandonment.

Municipal Authority under General Statutes 7-148

Application: The defendant acted within its municipal powers to install a gate to manage traffic and improve safety, which outweighed the plaintiffs’ claimed access rights.

Reasoning: The General Statutes 7-148 outlines various municipal powers, including regulating traffic, abating nuisances, ensuring public safety, and managing public land use, all of which support the defendant’s actions in maintaining road safety and access regulation.