The nonjoinder of a party will generally implicate the court's subject matter jurisdiction and require dismissal if a statute mandates the naming and serving of the party; however, the Connecticut Supreme Court in the 1981 case of Swenson v. Ditner, established that the failure to join such parties in an action to quiet title under C.G.S. §47-31 does not constitute error.
D'Appollonio v. Griffo-Brandao
Connecticut Appellate Court
October 8, 2012
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