Deutsche Bank AG v. Sebastian Holdings, Inc., 331 Conn. 379

Summary

The Connecticut Supreme Court affirmed the Appellate Court’s judgment in consolidated interlocutory appeals concerning the preclusive effect of an English judgment. The court held that the plaintiff’s corporate veil-piercing claim was not barred by res judicata and that the English court’s factual findings did not collaterally estop the individual defendant from contesting personal liability. The Supreme Court adopted the Appellate Court’s opinion without repeating its analysis.

Holdings

1. The corporate veil-piercing claim was not barred by res judicata because it was not the same claim as the contractual claims litigated in the English action; it sought to enforce the unsatisfied English judgment against Vik under a veil-piercing theory.
2. Deutsche Bank was not entitled to summary judgment on collateral-estoppel grounds because the English court's findings concerning Vik's domination and control of Sebastian were nonessential to the English judgment.
3. The findings from the English postjudgment costs proceeding were not entitled to preclusive effect because the issues were not identical and the proceeding did not provide the same procedural safeguards as the underlying merits action or the Connecticut action.

Questions Presented

1. Whether res judicata barred Deutsche Bank's Connecticut corporate veil-piercing claim because Deutsche Bank could have asserted that claim in the prior English action.
2. Whether collateral estoppel entitled Deutsche Bank to summary judgment based on factual findings in the English action allegedly establishing that Vik was Sebastian's alter ego.
3. Whether factual findings made in the English postjudgment costs proceeding were entitled to preclusive effect in the Connecticut action.

Disposition

affirmed