Farmington Valley Recreational Park, Inc. v. Farmington Show Grounds, LLC
The doctrine of res judicata applies if the following elements are satisfied: the identity of the parties to the actions are the same; the same claim, demand or cause of action is at issue; the judgment in the first action was rendered on the merits; and the parties had an opportunity to litigate the issues fully. In this mortgage foreclosure action concerning Farmington property known as the polo grounds, the defendants, Claude Brouillard, Farmington Equestrian Center, LLC and Farmington Show Grounds, LLC, appealed from the judgment of strict foreclosure. The defendants claimed that the trial court improperly concluded that the plaintiffs, including Farmington Show Grounds, LLC, proved ownership of the note for standing to commence the action and established the debt. The Appellate Court affirmed the judgment. The plaintiffs argued that the defendants failed to raise its claim challenging the plaintiffs' standing before the trial court and, therefore, the claim was unreviewable. The Appellate Court agreed that the claim was not raised below but reviewed it because the issue of standing implicated the court's subject matter jurisdiction. The record disclosed that the plaintiffs placed into evidence, without objection, the signed note, mortgage deed and security agreement. The trial court found that the plaintiffs proved they were the holders of the note. The defendants did not demonstrate that this finding was clearly erroneous. The defendants' second claim was that the amount of the debt was reduced in a modification agreement and the issue of the note being modified was litigated in a 2011 Hartford Superior Court case, Farmington Savings Bank v. Brouillard. The trial court found that the plaintiffs were not parties to the modification agreement. Therefore, the agreement did not reduce the amount owed. Res judicata did not apply because the claim in the bank's case was not the claim asserted by the plaintiffs in this case. The issue determined was the amount of debt owed to the bank, not the debt owed to these plaintiffs. Although the prior court may have concluded, or stated, that the debt owed to the plaintiffs was reduced by $300,000 that was not an issue that needed to be determined in the bank's case. The trial court in this case properly concluded that this prior finding was mere dicta.