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DRAFT FOR ATTORNEY REVIEW — NOT FINAL

Dorfman v. Smith, 342 Conn. 582 (2022)

Citation
Dorfman v. Smith, 342 Conn. 582 (2022)
Parent Document
Dorfman v. Smith, 342 Conn. 582 (2022)
Jurisdiction
Connecticut (state)
Effective Date
2022-03-29

Other Sections in This Document (164)

Full Text

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. . . Bad faith in general implies both actual or con-
         structive fraud, or a design to mislead or deceive
         another, or a neglect or refusal to fulfill some duty or
         some contractual obligation, not prompted by an honest
         mistake as to one’s rights or duties, but by some inter-
         ested or sinister motive. . . . Bad faith means more
         than mere negligence; it involves a dishonest purpose.’’
         (Internal quotation marks omitted.) Capstone Building
         Corp. v. American Motorists Ins. Co., 308 Conn. 760,
         794–95, 67 A.3d 961 (2013). ‘‘[V]iolations of express
         duties are necessary to maintain a bad faith cause of
         action.’’ Id., 797.
            In the present case, the majority concludes that,
         because the plaintiff’s bad faith claim is based on
         alleged misconduct during the litigation, it is barred by
         the litigation privilege. See part II of the majority opin-
         ion. In part II B of this opinion, I explain why I disagree
         with the majority’s conclusion that the plaintiff’s bad
         faith claim is based exclusively on litigation conduct
         and why the prelitigation misconduct at issue is action-
         able in a bad faith claim under Connecticut law. In part
         II C, I explain why, to the extent that the claim is based
         on litigation conduct, the majority’s analysis fails to
         adequately grapple with the relevant legal principles.
                                      B
            In the operative complaint, the plaintiff alleges that
         the defendant ‘‘agreed to pay [her] all sums [that she]
         was legally entitled to recover from the owner or opera-
         tor of an uninsured or underinsured motor vehicle for
         damages resulting from bodily injury sustained by [her]
         in an accident involving the maintenance or use of the
         uninsured or underinsured motor vehicle, up to the
         limits of its contract.’’ Although the operative complaint
         is not a model of clarity, it fairly can be read as also
         alleging that all of the conditions for the performance
         of the defendant’s obligation to pay her for her bodily
Page 94                         CONNECTICUT LAW JOURNAL                              March 29, 2022