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How to Write a Legal Complaint in Connecticut

Writing a legal complaint in Connecticut involves a series of structured steps that ensure clarity and adherence to state procedural requirements. A complaint is the foundational document in a civil lawsuit, outlining the plaintiff’s claims and the relief sought. Below, we explain how to write a legal complaint in Connecticut in a Superior Court, not a small claims court. We’ll discuss the different components of a complaint with reference to the sample below.

Sample Legal Complaint in Connecticut

DOCKET NO.: HHD-CV25-5678912

Taylor, James & Robinson, Kara

V.

Premier Home Solutions LLC, Et Al.

Superior Court

J.D. At New Haven

At New Haven

January 15, 2025

COMPLAINT

COUNT ONE: BREACH OF CONTRACT

  1. The Plaintiffs, James Taylor and Kara Robinson, are individuals and residents of the state of Connecticut.
  2. The Defendant, Premier Home Solutions LLC, is a Connecticut Limited Liability Corporation with a principal place of business in New Haven, Connecticut. The Defendants, Michael Brown and Dana Lee, are individuals and residents of the state of Connecticut.
  3. Plaintiffs contracted with the Defendants, Premier Home Solutions LLC, for home improvement work to be done on Ms. Robinson’s property at 72 Hilltop Lane, Branford, CT, 06405, on or about April 10, 2024, for a contracted price of $18,450.00.
  4. The scope of the work included renovations to the kitchen, installation of new windows, and repairs to the roof.
  5. Plaintiffs paid a down payment of $7,000.00 to Defendants on or about April 10, 2024.
  6. Plaintiffs made additional payments totaling $14,500.00 through May 15, 2024.
  7. Both parties collaborated with Coastal Designs LLC of Milford, CT, to select materials and finalize plans for the kitchen renovation.
  8. Defendants began work on the project but failed to complete the agreed-upon renovations, citing disagreements over design changes and scheduling.
  9. Defendants breached the agreement by failing to complete the work, damaging Plaintiffs’ property by improperly installing windows, leaving roofing materials exposed to weather damage, and failing to perform the work in a professional manner.

WHEREFORE, the Plaintiffs claim:

  1. Monetary damages;
  2. Costs of suit;
  3. Attorney fees as allowed by statute;
  4. Such other relief as the Court finds just and equitable.

COUNT TWO: VIOLATION OF THE HOME IMPROVEMENT ACT

1.–8. The allegations of paragraphs 1 through 8, inclusive, of the first count, are hereby made allegations of this the second count, as if fully set forth herein.
9. The Plaintiff, Kara Robinson, is an “owner” as defined by C.G.S. § 20-419(6).
10. The Defendant, Premier Home Solutions LLC, is a “contractor” as defined by C.G.S. § 20-419(3).
11. The contract entered into between the parties constitutes a “home improvement contract” as defined by C.G.S. § 20-419(5).
12. The contract did not include required terms such as a starting date, completion date, or cancellation notice as required under C.G.S. § 20-429(a)(1)(A)(vii).
13. As a result, the Defendants have violated the Connecticut Home Improvement Act.

WHEREFORE, the Plaintiffs claim:

  1. Monetary damages;
  2. Costs of suit;
  3. Attorney fees as allowed by statute;
  4. Such other relief as the Court finds just and equitable.

COUNT THREE: VIOLATION OF THE CONNECTICUT UNFAIR TRADE PRACTICES ACT (CUTPA)

1.–13. The allegations of paragraphs 1 through 13, inclusive, of the second count, are hereby made allegations of this the third count, as if fully set forth herein.
14. The Plaintiffs, James Taylor and Kara Robinson, are each a “person” as defined by C.G.S. § 42-110a(3).
15. The Defendants engaged in trade and commerce in their dealings with the Plaintiffs as defined by C.G.S. § 42-110a(4).
16. Pursuant to C.G.S. § 20-427(c), “[a] violation of any of the provisions of this chapter shall be deemed an unfair or deceptive trade practice under subsection (a) of section 42-110b.”

WHEREFORE, the Plaintiffs claim:

  1. Monetary damages, both actual and punitive;
  2. Costs of suit;
  3. Attorney fees as allowed by statute;
  4. Such other relief as the Court finds just and equitable.

THE PLAINTIFFS,
BY: /s/ Jonathan L. Cruz
JONATHAN L. CRUZ
ATTORNEY AT LAW
65 Maple Street
Suite 202
New Haven, CT 06510
Tel: (203) 555-1234
Email: jonathan@cruzlawct.com
Juris No.: 509876

Separate Page

DOCKET NO.: HHD-CV25-5678912

Taylor, James & Robinson, Kara

V.

Premier Home Solutions LLC, Et Al.

Superior Court

J.D. At New Haven

At New Haven

January 15, 2025

STATEMENT REGARDING AMOUNT IN DEMAND

The amount in demand, exclusive of interest and costs, exceeds FIFTEEN THOUSAND ($15,000.00) DOLLARS as to each count.

THE PLAINTIFFS
BY: /s/ Jonathan L. Cruz
JONATHAN L. CRUZ
ATTORNEY AT LAW

Separate Page

CERTIFICATION OF SERVICE

I certify that a copy of the foregoing was mailed or delivered electronically or non-electronically on 01/15/2025 to all counsel and self-represented parties of record. Written consent for electronic delivery was received from the party receiving electronic delivery.

Attorney for Defendants:
Michael D. Stone, Esq.
stone@premierlawfirm.com


BY: /s/ Jonathan L. Cruz
JONATHAN L. CRUZ, ESQ.
Attorney at Law
Commissioner of the Superior Court

1. Caption and Docket Information

The caption includes critical identifying information about the case.

DOCKET NO.: HHD-CV25-5678912Superior Court
Taylor, James & Robinson, KaraJ.D. At New Haven
V.At New Haven
Premier Home Solutions LLC, Et Al.January 15, 2025

Key Elements:

  • Docket Number: Assigned by the court after filing (e.g., “DOCKET NO.: HHD-CV25-5678912”).
  • Parties: Clearly state the names of the plaintiffs and defendants. For example:
    • Plaintiffs: “Taylor, James & Robinson, Kara.”
    • Defendants: “Premier Home Solutions LLC, Et Al.”
  • Court Information: Specify the court where the case is filed (e.g., “Superior Court, J.D. At New Haven”).
  • Date and Location: Indicate the filing date and judicial district (e.g., “At New Haven, January 15, 2025”).

When you write a legal complaint in Connecticut, including accurate docket information is crucial to ensure proper filing and identification.

2. Title of the Complaint

The title should clearly identify the document as a “Complaint” or “Amended Complaint,” depending on whether it is the initial or amended version. This is a key part of how to write a legal complaint in Connecticut to distinguish the document’s purpose.

3. Introduction to the Counts

A complaint is divided into counts, with each count addressing a specific legal claim. For example:

  • Count One: Breach of Contract
  • Count Two: Violation of the Home Improvement Act
  • Count Three: Violation of the Connecticut Unfair Trade Practices Act (CUTPA)

Each count contains its own set of allegations and specific relief sought. Breaking down your claims into counts is a best practice when you write a legal complaint in Connecticut.

4. Allegations

The allegations form the factual and legal foundation for the complaint. A count may begin with an incorporation clause, referencing prior allegations.

Key Points to Include:

  1. Identify the Parties:
    • State who the plaintiffs and defendants are, including their residency and business information (e.g., “The Defendant, Premier Home Solutions LLC, is a Connecticut Limited Liability Corporation with a principal place of business in New Haven, Connecticut.”).
  2. Describe the Contract or Relationship:
    • Specify the agreement or relationship that gives rise to the claims. For example, “Plaintiffs contracted with Defendants for home improvement work on April 10, 2024, for $18,450.00.”
  3. Detail the Breach or Wrongdoing:
    • Explain how the defendants’ actions constitute a breach or violation. For instance, in Count One, the complaint states, “Defendants breached the agreement by failing to complete the work and damaging Plaintiffs’ property.”
  4. Number the Paragraphs:
    • When writing a legal complaint in Connecticut, ensure every paragraph is numbered sequentially for clarity and ease of reference. This practice helps the court, opposing counsel, and other parties quickly locate specific allegations or claims within the document.
  5. Cite Relevant Laws (Optional):
    • Include statutory references for claims under specific laws, such as the Home Improvement Act (C.G.S. § 20-419) or CUTPA (C.G.S. § 42-110b).

When learning how to write a legal complaint in Connecticut, ensuring detailed and precise allegations strengthens your case and makes it easier for the court to understand your claims.

5. Relief Sought

At the end of each count, specify the relief sought by the plaintiffs. Common forms of relief include:

  • Monetary Damages: Compensation for losses.
  • Costs of Suit: Recovery of court costs.
  • Attorney Fees: If allowed by statute (e.g., CUTPA) or another law.
  • Equitable Relief: Any non-monetary remedy deemed just by the court.

For example, under each count, the complaint concludes with:

WHEREFORE, the Plaintiffs claim:

  1. Monetary damages;
  2. Costs of suit;
  3. Attorney fees as allowed by statute;
  4. Such other relief as the Court finds just and equitable.

Understanding how to clearly state the relief sought is an essential aspect of how to write a legal complaint in Connecticut.

6. Statement Regarding Amount in Demand

In Connecticut, civil complaints must include a statement regarding the amount in demand. This clarifies whether the claim exceeds a specified monetary threshold (e.g., $15,000). For example:

STATEMENT REGARDING AMOUNT IN DEMAND

The amount in demand, exclusive of interest and costs, exceeds FIFTEEN THOUSAND ($15,000.00) DOLLARS as to each count.

This requirement is specific to Connecticut law, and addressing it properly ensures compliance when you write a legal complaint in Connecticut.

7. Attorney Information and Signature

The attorney or pro se litigant filing the complaint must include their name, address, email, and if applicable, juris number. This ensures proper identification and communication. For example:

JONATHAN L. CRUZ
65 Maple Street, Suite 202
New Haven, CT 06510
Tel: (203) 555-1234
Email: jonathan@cruzlawct.com
Juris No.: 509876

The attorney’s or pro se litigant’s signature should also be including, confirming the filing. Adding this information correctly is a critical step when you write a legal complaint in Connecticut.

8. Certificate of Service

A certificate of service is a required part of a legal complaint, verifying that all parties involved in the case have been provided with a copy of the filed complaint. This ensures transparency and compliance with procedural rules.

Key Elements to Include:

  • Date of Service: Indicate the date the complaint was served (e.g., “01/15/2025”).
  • Delivery Method: Specify whether the complaint was delivered electronically, non-electronically, or both.
  • Recipient Details: Include the names and addresses of all attorneys or self-represented parties served.
  • Certification Statement: A declaration that the service was completed as required by law. For example:

“I certify that a copy of the foregoing was mailed or delivered electronically or non-electronically on 01/15/2025 to all counsel and self-represented parties of record. Written consent for electronic delivery was received from the party receiving electronic delivery.”

Including a certificate of service is critical when you write a legal complaint in Connecticut to confirm compliance with court rules.

By following these steps, you can draft a clear, well-organized legal complaint that adheres to Connecticut’s procedural requirements. The sample complaint provided demonstrates these principles in practice, making it a valuable starter template for anyone learning how to write a legal complaint in Connecticut.

Read Next: How to Electronically File Court Documents in Connecticut

Disclaimer: The information provided is for educational and informational purposes only and should not be construed as legal advice. The use of this information does not create an attorney-client relationship, and any communication with our service through this platform does not establish an attorney-client relationship. You should consult an experienced attorney for advice specific to your individual situation, as each case is unique and requires careful consideration of all relevant factors.