Johnson Electric Co. v. Salce Contracting Associates, Inc

In Johnson Electric Co. v. Salce Contracting Associates, Inc., 72 Conn. App. 342, 344, 805 A.2d 735, cert. denied, 262 Conn. 922, 812 A.2d 864 (2002), the plaintiff subcontractor brought an action against the defendant general contractor, alleging that the defendant had violated CUTPA when it failed to award the plaintiff a subcontract for electrical work on a school project, despite the fact that the defendant, who had been required to "name" its subcontractors on the bid, had named the plaintiff as the subcontractor for the electrical work. Id. "The trial court held that, because the plaintiff did not prove that the defendant had engaged in a repeated course of misconduct, the plaintiff did not establish that the defendant violated CUTPA." Id., 349. This court reversed the judgment of the trial court and concluded that "the trial court improperly declined relief to the plaintiff on the ground that it had alleged and proven only a single act of misconduct." Id., 353. In so doing, the Court made it clear that a single act of misconduct may constitute a violation of CUTPA.