Ligeri v. White Road Capital, LLC, Series 168814

Syllabus

The plaintiff appealed from the trial court's judgment granting, on standing grounds, motions to dismiss filed by the defendants. He claimed, inter alia, that the court improperly concluded that he lacked standing to prosecute the underyling action because he was not a party to the contracts that formed the basis of the action. Held: The trial court did not abuse its discretion in denying the plaintiff's request for an evidentiary hearing in accordance with Standard Tallow Corp. v. Jowdy (190 Conn. 48), as the plaintiff never claimed before the court that any disputed issues of fact needed to be resolved with respect to whether he was a proper party to invoke judicial resolution of the disputes alleged in the complaint. The trial court properly dismissed the action as to all defendants with respect to the count of the plaintiff's complaint seeking a declaratory judgment, as the plaintiff failed to demonstrate that he was the proper party to request the declaratory relief sought because that request arose entirely out of contracts between a nonparty, C Co., and the defendants, the plaintiff was not a party to those contracts, and, although, he was an individual guarantor of C Co.'s performance obligations, that status was not sufficient to confer standing on the plaintiff in his individual capacity. The trial court improperly dismissed three counts of the plaintiff's complaint directed against the defendant A Co. that sound in tortious interference with business expectancies, negligent misrepresentation, and a violation of the Connecticut Unfair Trade Practices Act (§ 42-110a et seq.), as the allegations made in support of those counts, namely, that A Co.'s unauthorized or illegal actions resulted in the freezing of the plaintiff's personal PayPal account, demonstrated that he arguably had some direct and personal interest in those causes of action. Argued September 15, 2025—officially released March 10, 2026