Melfi v. Danbury
In Melfi v. Danbury, 70 Conn. App. 679, 800 A.2d 582, cert. denied, 261 Conn. 922, 806 A.2d 1061 (2002), the Court addressed the issue of the failure to award nominal damages.
"It was improper for the trial court to fail to award damages to the plaintiffs. Because liability already had been conclusively established . . . the plaintiffs, at the very least, were entitled to nominal damages. Although technically incorrect, the failure to award damages does not require a remand. No purpose would be furthered by a remand because the damages to be awarded to the plaintiff against the defendants could only be nominal based upon the substantive findings of the trial court . . . . We will not ordinarily remand a case for the mere failure to award nominal damages." Id., 691-92.