Cunha v. Colon
In Cunha v. Colon, 260 Conn. 15, 792 A.2d 832 (2002), the Court held that the lessor and lessee of an automobile were not joint tortfeasors within the meaning of 52-572e and, consequently, that a release executed in favor of a lessee also operates to release the lessor. Cunha v. Colon, supra, 260 Conn. at 17.
The court stated that " 52-572e was intended to apply only to joint tortfeasors who are independently at fault on the basis of their own tortious conduct, and not to individuals or entities whose sole liability is derivative or vicarious in nature." 260 Conn. at 20.