Bank of America, N.A. v. Street

Syllabus

The defendant property owners appealed from the trial court's judgment of strict foreclosure rendered for the second substitute plaintiff, C Co. The defendants claimed that the court improperly granted C Co.'s motion for summary judgment because, inter alia, a genuine issue of material fact existed as to whether the original plaintiff, A Co., had standing when it commenced the action. Held: This court affirmed the trial court's judgment on an alternative ground, as the record unequivocally indicated that the trial court properly granted A Co.'s motion to substitute the first substitute plaintiff, the real party in interest, pursuant to the rule of practice (§ 9-20), thus curing any jurisdictional defect that may have existed when A Co. commenced the action. The trial court did not abuse its discretion in denying the defendants' requests to conduct additional discovery prior to the court's ruling on C Co.'s motion for summary judgment, as the defendants did not provide any valid reason why C Co.'s motion for summary judgment should have been denied or the ruling delayed due to their requested discovery, and the defendants' reli- ance on JPMorgan Chase Bank, National Assn. v. Lakner (347 Conn. 476) was misplaced, as that case was inapplicable because the defendants in the present case not only received discovery, but received the very discovery required by the court to affirmatively decide the standing issue raised by the defendants in summary judgment. Argued December 15, 2025—officially released March 24, 2026