Paquette v. Thompson

Paquette · Connecticut Appellate Court · April 7, 2026 · No. AC 47625

Summary

The Connecticut Appellate Court affirmed a judgment awarding interpleaded real-property sale proceeds to Randall Paquette rather than 53 Westwood Lane, LLC, or Gary Thompson. The court held that the Connecticut Limited Liability Company Act in effect in 2009 governed Thompson’s transfer of his entire membership interest, rather than the Connecticut Uniform Limited Liability Company Act that took effect in 2017. Applying the earlier statute, the court upheld the trial court’s determination that Paquette became Westwood Lane’s sole member and was entitled to the disputed funds.

Holdings

  1. The Connecticut Limited Liability Company Act, General Statutes (Rev. to 2009) § 34-100 et seq., governed the legal effect of Thompson's transfer of his membership interest in 2009; the Connecticut Uniform Limited Liability Company Act, General Statutes § 34-243 et seq., effective July 1, 2017, did not govern.
  2. Under General Statutes (Rev. to 2009) § 34-172 (d), Thompson ceased to be a member of Westwood Lane when he transferred all of his membership interest to Paquette, who was already a member; Paquette thereby became the sole member.
  3. The trial court did not clearly err in determining that Paquette, rather than Westwood Lane, was entitled to the disputed proceeds.
  4. Thompson lacked standing to assert Westwood Lane's claim to the disputed funds because he claimed no personal entitlement and had ceased to be a member of Westwood Lane.

Questions Presented

  1. Whether the legal effect of Thompson's 2009 transfer of all of his membership interest in Westwood Lane was governed by the Connecticut Limited Liability Company Act in effect in 2009 or by the Connecticut Uniform Limited Liability Company Act effective in 2017.
  2. Whether, under the law in effect in 2009, Thompson ceased to be a member of Westwood Lane when he transferred his entire membership interest to Paquette, who was already a member.
  3. Whether the trial court clearly erred in determining that Paquette, rather than Westwood Lane, was entitled to the disputed sale proceeds.
  4. Whether Thompson had standing to assert a claim on behalf of Westwood Lane.
  5. Whether the trial court's finding that Thompson breached a contractual agreement affected the judgment awarding the disputed funds.

Disposition

affirmed

Cases Cited (18)

  • John Hancock Life Ins. Co. v. Curtin, 219 Conn. App. 613, 621, 295 A.3d 1055, cert. granted on other grounds, 348 Conn. 921, 304 A.3d 147 (2023) (appeal withdrawn November 22, 2024)(followed)
  • Meadowbrook Center, Inc. v. Buchman, 328 Conn. 586, 594, 181 A.3d 550 (2018)(followed)
  • RCN Capital, LLC v. Sunford Properties & Development, LLC, 196 Conn. App. 823, 829, 231 A.3d 201 (2020)(followed)
  • In re Francisco R., 111 Conn. App. 529, 536, 959 A.2d 1079 (2008)(followed)
  • Loch View, LLC v. Windham, 237 Conn. App. 462, 486, A.3d (2026)(followed)
  • Deming v. Nationwide Mutual Ins. Co., 279 Conn. 745, 780, 905 A.2d 623 (2006)(followed)
  • Tyler v. Schnabel, 34 Conn. App. 216, 220–21, 641 A.2d 388 (1994)(followed)
  • Curley v. Phoenix Ins. Co., 220 Conn. App. 732, 754, 299 A.3d 1133, cert. denied, 348 Conn. 914, 303 A.3d 260 (2023)(followed)
  • Rubin v. Brodie, 228 Conn. App. 617, 634, 325 A.3d 1096 (2024)(followed)
  • Prescott v. Gilshteyn, 227 Conn. App. 553, 575–76, 322 A.3d 1060, cert. denied, 350 Conn. 926, 326 A.3d 248 (2024)(followed)

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