Galvanek v. Skibitcky
In Galvanek v. Skibitcky, 55 Conn. App. 254, 738 A.2d 1150 (1999), the Court held that "'where, pursuant to an agreement, money is left in the hands of the attorney or agent of one of the parties, the money is not delivered in escrow.'"
Applying that principle to the facts in that case, the Court concluded that because the money was held by the plaintiff's attorney, and the interest of the plaintiff and his attorney were identical, the plaintiff's attorney never acquired the independent status as an escrow agent and, therefore, the money was not held in escrow. Id.