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business in the state. There were no critical facts sought emotional distress for having to undergo
relating to jurisdiction under the statute. Next, further blood testing, those damages were too
the court determined that exercising jurisdiction individualized to be resolved on a class-wide
would not violate constitutional principles of basis. The court granted class certification as to
due process. The club conceded that it conduct- professional negligence, but the court also found
ed group rides in Connecticut. Its activities and that recklessness required individual findings of
events comported with and fulfilled purposes causation, and denied class certifications as to
for which the club was formed. Accordingly, the the recklessness counts.
club purposefully availed itself of the privileg-
es of conducting activities within Connecticut,
thereby invoking the benefits and protection of CONTRACTUAL DISPUTES

the state’s laws. Further, the club presented no Towing Company Entitled to Payment
compelling argument that jurisdiction would be
unreasonable. The accident happened in Con- for Services Rendered
necticut. Evidence and witnesses were likely
to be located in Connecticut. The club’s office CASE: Farmington Auto Park, LLC v. Allstate Ins. Co.
of incorporation was in Westchester County, a COURT: New Britain J.D.
nearby location. Considering the totality of all DOC. NO.: CV19-6050993
these factors, the assertion of personal jurisdic- COURT OPINION BY: Shortall
tion would comport with traditional notions of DATE: November 24, 2020 • PAGES: 4
fair play and substantial justice.
The court rendered judgment in favor of plain-
tiff, finding it was entitled to payment of most of
the items on its invoice. A dispute arose between
CLASS ACTIONS • HEALTH CARE LAW the parties as to the proper amount payable to
plaintiff for its services in recovering a vehicle
Court Grants Class Certification as from the scene of an accident, conducting pre-
liminary repair work, and storing the vehicle on
to Professional Negligence, but Not its premises. Plaintiff sued defendant to recover
Recklessness payment for its services. The trial court rendered
judgment in favor of plaintiff, finding (1) plain-
CASE: Diaz v. Griffin Health Serv. Corp. tiff’s estimated cost to repair the vehicle did not
COURT: Waterbury J.D., Complex Litigation Docket exceed the vehicle’s book value; (2) the $1,800
DOC. NO.: CV-156029965 previously paid by defendant was not accepted
COURT OPINION BY: Lager by plaintiff as “full and final” settlement of its
DATE: November 23, 2020 • PAGES: 19
The named plaintiffs were admitted to the de- claim; and (3) defendant’s insured, the owner of
fendant Griffin Hospital between 2009 and 2014 the vehicle, knowingly and voluntarily consented
and were prescribed and administered insulin to the $100 daily storage rate included in plain-
from a multi-dose insulin pen. In 2014 it was tiff’s invoice. The court disallowed a $281.53 “ad-
discovered that several hospital employees were ministration fee” on plaintiff’s invoice, but found
improperly using the pens, including using the plaintiff was otherwise allowed the full amount
same pen on different patients, and removing claimed, $1,572.43, plus costs and reasonable
patient identification labels on pens and admin- attorney fees in the amount of $1,000.
istering insulin from the pen to other patients.
According to an investigation by the Depart-
ment of Public Health, the improper uses may CYBERSECURITY •
have resulted in transmission of blood-borne GOVERNMENT • PRIVACY

pathogens. Plaintiffs brought claims of profes- Court Finds “Constituents Units” Not
sional negligence and recklessness in adminis-
tering the multi-dose pens, and moved for class Included in “Agency” under Public Data
certification to include all patients subjected to Act for Sovereign Immunity Purposes
the multi-dose pens. The court found the liabil-
ity issues and proximate cause for professional CASE: Martinez v. Univ. of Connecticut
negligence were common among the class, and COURT: New London J.D. at New London
that class resolution was a superior method of DOC. NO.: CV-20-6044714
resolving both. However, the court found that, COURT OPINION BY: Knox
to the extent that any of the class members DATE: November 23, 2020 • PAGES: 11

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