State v. Salmon
In State v. Salmon, 250 Conn. 147, 162 735 A.2d 333 (1999) the Court considered whether a bonding agency, which was not a party to the underlying criminal action, could appeal pursuant to 52-263, from the trial court's order to forfeit its bond. The court concluded that the bonding agency, as a nonparty, had no such right to appeal. Id., 162.
Following a lengthy discussion regarding the parameters of the "party" requirement of 52-263, the court in Salmon concluded that the term party is limited to parties to the underlying action.
In so holding, the Supreme Court overruled certain of its precedents "to the extent that those precedents imply that a person or legal entity that is not a party to the underlying action constitutes a party for purposes of appellate review pursuant to 52-263 . . . ." State v. Salmon, supra, 250 Conn. 155.
The court went on to adopt "a bright-line test requiring the appellant, in order to establish a right of appellate review pursuant to 52-263, to establish in the following sequence that: (1) it was a party to the underlying action; (2) it was aggrieved by the trial court decision; and (3) the appeal is from a final judgment." Id., 162-63.