Rioux v. Barry, 283 Conn. 338

Summary

The Supreme Court of Connecticut held that absolute immunity does not bar a vexatious litigation claim based on statements made in a quasi-judicial proceeding. It held, however, that absolute immunity does bar an intentional interference with contractual or beneficial relations claim based on the same statements, reversing in part and affirming in part the trial court's judgment.

Holdings

1. Absolute immunity does not attach to statements that provide the ground for a tort of vexatious litigation, even when the statements were made in the course of a judicial or quasi-judicial proceeding.
2. Absolute immunity bars a claim for intentional interference with contractual or beneficial relations when the alleged interference consists of statements made in the course of a judicial or quasi-judicial proceeding.

Questions Presented

1. Whether absolute immunity for statements made during a quasi-judicial proceeding bars a claim for vexatious litigation.
2. Whether the same absolute immunity bars a claim for intentional interference with contractual or beneficial relations based on those statements.
3. Whether the trial court properly dismissed both claims under the applicable immunity doctrine.

Disposition

reversed_and_remanded