Background
Between-the-Bridges, LLC operates a commercial marina in Old Saybrook, Connecticut. After a vessel owned by Bob and Joanne Abbott was damaged by flooding in July 2020, the plaintiff secured and stored it at the facility. In August or September 2020, defendant James S. O’Rourke purchased the vessel from the Abbotts and agreed to keep it at the marina for reconstruction. The plaintiff discussed storage fees with the defendant and later invoiced him for accrued charges totaling approximately $17,636, but the defendant never paid.
In October 2022, the plaintiff filed suit for unjust enrichment and sought prejudgment remedies. A bench trial was conducted in July 2024, and the trial court rendered judgment in the plaintiff’s favor, awarding $17,636 on the unjust enrichment claim. The court also issued an order permitting the defendant to remove the vessel within twenty-one days, with a penalty of $215 per month if removal was not completed. The plaintiff appealed, challenging both the removal order and the court’s failure to award postjudgment interest pursuant to Connecticut General Statutes § 37-3a.
The Court’s Holding
The Connecticut Appellate Court reversed in part. First, the court found the trial court erred in issuing an order authorizing vessel removal because the defendant had never actually requested such relief. Although the defendant filed a pretrial motion seeking permission to remove the vessel, the trial court denied that motion. The defendant did not renew the request in his counterclaim, trial testimony, or posttrial brief. Finding no legal basis for the court to award relief that was never requested, the appellate court vacated the removal order entirely.
Second, regarding postjudgment interest, the court affirmed the trial court’s implicit denial. Although the plaintiff had requested postjudgment interest in its complaint’s prayer for relief, it failed to raise the issue at trial, in its posttrial brief, or before the corrected memorandum of decision was issued. The appellate court concluded the plaintiff had abandoned the claim through inadequate briefing and procedural default, and therefore the trial court reasonably declined to award it.
Key Takeaways
- Trial courts lack authority to award relief that a party has not requested, even if doing so might benefit the claimant.
- Postjudgment interest under Connecticut law is discretionary and must be affirmatively raised and briefed; failure to address it in posttrial proceedings constitutes abandonment.
- Procedural defaults, such as failing to brief an issue, prevent parties from reviving claims in post-judgment motions seeking reconsideration.
Why It Matters
This decision reinforces critical procedural principles in Connecticut practice. For litigants, it establishes that all requested relief must be explicitly pursued throughout the trial process—claims not briefed or highlighted to the court before the final decision may be deemed abandoned and cannot be rescued through post-judgment motions. The decision also clarifies that postjudgment interest, while potentially recoverable, requires affirmative advocacy and cannot be assumed to pass by judicial notice simply because it appears in an initial prayer for relief months before trial.
For trial courts, the holding reaffirms that judicial authority derives from the parties’ requests and the scope of relief properly pleaded. Courts cannot exceed those bounds even with arguably beneficial intentions. This reflects the principle that our adversarial system depends on parties advancing their own cases rather than courts sua sponte ensuring all available remedies are pursued.