Waterman v. United Caribbean, Inc
In Waterman v. United Caribbean, Inc., 215 Conn. 688, 577 A.2d 1047 (1990), the trial court contacted the parties prior to judgment and asked them to consent to an extension of time. Id., at 690. Both by telephone and by letter, the defendants refused to agree to an extension. Id.
The trial court thereafter issued an abbreviated memorandum of decision indicating that its ruling substantially was in favor of the defendants. Id. The defendants then attempted to consent to the late rendering of the judgment. Id.
On appellate review, our Supreme Court reversed this court's holding that the defendants' belated consent was effective, reasoning that "the defendants' initial refusal to consent to a late judgment deprived the court of personal jurisdiction over them." Id., at 694.
"By their conduct, they made the judgment, when rendered, not merely voidable, but void. Although a voidable judgment may be cured, a void one may not. The defendants' execution of a consent following the late judgment's issuance therefore had no legal effect." Id.