Michel v. Hartford, 226 Conn. App. 98 (2024)

Citation: Michel v. Hartford, 226 Conn. App. 98 (2024)
Parent Document: Michel v. Hartford, 226 Conn. App. 98 (2024)
Jurisdiction: Connecticut (state)
Effective Date: 2024-06-11
Original Source: https://www.courtlistener.com/opinion/10131855/michel-v-hartford/ ↗

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of the operative complaint was barred by the statute of limitations. The
         court did not resolve the motion to strike as to count one on this ground,
         reasoning that the issue of the statute of limitations typically must be pleaded
         as a special defense, rather than by a motion to strike. See Greco v. United
         Technologies Corp., 277 Conn. 337, 344 n.12, 890 A.2d 1269 (2006) (‘‘[O]rdi-
         narily, [a] claim that an action is barred by the lapse of the statute of
         limitations must be pleaded as a special defense, not raised by a motion to
         strike. . . . This is because a motion to strike challenges only the legal
         sufficiency of the complaint and might . . . deprive a plaintiff of an opportu-
         nity to plead matters in avoidance of the statute of limitations defense.’’
         (Citations omitted; internal quotation marks omitted.)).
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