SR Holdings I, LLC v. Cannavo

Syllabus

The plaintiff appealed from the trial court's judgment ordering the remit- titur of the damages the jury had awarded to the plaintiff in connection with its claims of fraudulent transfer relating to certain real property that was formerly owned by the defendant W Co. and transferred to the defendant B Co. The plaintiff claimed that the court had abused its discretion in reducing the award. W Co., B Co. and their defendant managing members separately appealed from the trial court's judgment, following its denial of their motion to set aside the verdict in its entirety. The defendants claimed that the court abused its discretion because, inter alia, B Co. provided reasonably equiva- lent value to W Co. in exchange for the transferred real property. This court consolidated the appeals. Held: This court dismissed the plaintiff's appeal for lack of subject matter jurisdic- tion, as the plaintiff accepted the remittitur and did not avail itself of the opportunity to decline the remittitur and pursue an appeal from the trial court's order pursuant to statute (§ 52-228a). The trial court did not abuse its discretion in denying the defendants' motion to set aside the verdict, as the jury could have reasonably found from the evidence in the record that the value of the liens encumbering the transferred properties did not exceed the total value of the properties, that the trans- ferred properties therefore were not overleveraged and, instead, constituted assets under the Connecticut Uniform Fraudulent Transfer Act (§ 52-552a et seq.), and that there was not reasonably equivalent value exchanged for the transferred properties because the total consideration furnished by B Co. was less than the market value of the properties. Argued January 7—officially released June 9, 2026