TABLE OF CONTENTS

1. Caption
2. Parties
3. Jurisdiction and Venue
4. Statutory Notice Compliance
5. Factual Allegations
6. Count I - Dram Shop Liability (Conn. Gen. Stat. § 30-102)
7. Count II - Negligence (Sale to Minor)
8. Damages
9. Jury Demand
10. Prayer for Relief
11. Verification
12. State-Specific Notes
13. Sources and References

CAPTION

SUPERIOR COURT OF CONNECTICUT
JUDICIAL DISTRICT OF [________________________________]
AT [________________________________]

[________________________________],
Plaintiff,

v.

[________________________________] (d/b/a [________________________________]),
Defendant(s).

Docket No.: [________________________________]
Return Date: [________________________________]

PARTIES

1. Plaintiff [________________________________] is a resident of [________________________________], Connecticut, and is the person injured as a result of the acts described herein.

2. Defendant [________________________________] (hereinafter "Seller Defendant") is a person or entity holding a permit to sell alcoholic liquor in Connecticut, operating as [________________________________], located at [________________________________], Connecticut.

3. [________________________________] (hereinafter "Intoxicated Person") was at all relevant times a patron who was sold alcoholic liquor by the Seller Defendant.

JURISDICTION AND VENUE

4. This Court has jurisdiction over this action pursuant to Conn. Gen. Stat. § 51-164s.

5. Venue is proper in this judicial district pursuant to Conn. Gen. Stat. § 51-345 et seq.

STATUTORY NOTICE COMPLIANCE

6. Pursuant to the mandatory notice requirement of Conn. Gen. Stat. § 30-102, Plaintiff provided written notice to the Seller Defendant on or about [__/__/____], which was within [____] days of the injury sustained on [__/__/____].

7. Said notice included:
   ☐ The name of the person to whom the alcoholic liquor was sold (purchaser)
   ☐ The date and time of the sale
   ☐ The name and address of the injured person
   ☐ The nature of the injuries sustained

8. A true and correct copy of the notice is attached hereto as Exhibit A.

FACTUAL ALLEGATIONS

9. On or about [__/__/____], the Intoxicated Person entered the Seller Defendant's premises at [________________________________].

10. The Seller Defendant, through its agents, employees, or servants, sold alcoholic liquor to the Intoxicated Person.

11. At the time of sale, the Intoxicated Person was intoxicated, as would be visibly or otherwise perceivable to a reasonable person, as evidenced by:

☐ Slurred speech
☐ Unsteady gait or impaired balance
☐ Glassy or bloodshot eyes
☐ Loud, disruptive, or aggressive behavior
☐ Difficulty with motor coordination
☐ Strong odor of alcohol
☐ Other: [________________________________]

12. Despite the Intoxicated Person's perceivable intoxication, the Seller Defendant sold alcoholic liquor.

13. Because of the intoxication caused by the sale, the Intoxicated Person [________________________________] [describe injurious conduct].

14. As a direct result, Plaintiff suffered injuries including but not limited to [________________________________].

COUNT I - DRAM SHOP LIABILITY (Conn. Gen. Stat. § 30-102)

15. Plaintiff re-alleges and incorporates paragraphs 1 through 14.

16. Pursuant to Conn. Gen. Stat. § 30-102, if any person, by the sale of alcoholic liquor, causes the intoxication of another, and the intoxicated person injures any other person or the property of any other person, the seller shall pay just damages to the injured person.

17. The Seller Defendant sold alcoholic liquor to the Intoxicated Person, causing or contributing to the Intoxicated Person's intoxication.

18. The Intoxicated Person, by reason of said intoxication, injured the Plaintiff.

19. Plaintiff has complied with the statutory notice requirement of § 30-102.

20. As a result, the Seller Defendant is liable to Plaintiff for just damages up to the statutory maximum.

COUNT II - NEGLIGENCE (Sale to Minor)

21. Plaintiff re-alleges and incorporates paragraphs 1 through 14.

22. At the time of sale, the Intoxicated Person was under the age of twenty-one (21).

23. The Seller Defendant, in violation of Conn. Gen. Stat. § 30-86(b)(2), sold alcoholic liquor to a minor.

24. The Seller Defendant knew or should have known the Intoxicated Person was under 21.

25. This statutory violation constitutes negligence.

26. The Seller Defendant's negligence was a proximate cause of Plaintiff's injuries.

DAMAGES

27. As a direct result of the Defendant's conduct, Plaintiff has suffered:

☐ Past and future medical expenses: $[________________________________]
☐ Past and future lost wages and earning capacity: $[________________________________]
☐ Pain and suffering: $[________________________________]
☐ Mental anguish and emotional distress: $[________________________________]
☐ Loss of enjoyment of life: $[________________________________]
☐ Property damage: $[________________________________]
☐ Other: [________________________________]

JURY DEMAND

28. Plaintiff hereby demands a trial by jury on all issues so triable.

PRAYER FOR RELIEF

WHEREFORE, Plaintiff respectfully requests that this Court:

a. Enter judgment against Defendant(s) and in favor of Plaintiff;
b. Award just damages up to the statutory maximum of $250,000 under Count I;
c. Award compensatory damages under Count II in an amount to be determined at trial;
d. Award pre-judgment and post-judgment interest;
e. Award costs of this action;
f. Grant such other and further relief as this Court deems just and proper.

VERIFICATION

STATE OF CONNECTICUT
COUNTY OF [________________________________]

I, [________________________________], being duly sworn, state that I have read the foregoing Complaint and that the facts stated therein are true and correct to the best of my knowledge, information, and belief.

_____________________________________________
[________________________________], Plaintiff

Sworn to and subscribed before me this [____] day of [________________________________], [____].

_____________________________________________
Commissioner of the Superior Court / Notary Public

Respectfully submitted,

THE PLAINTIFF,

_____________________________________________
[________________________________]
Attorney for Plaintiff
[________________________________]
[________________________________]
Juris No.: [________________________________]
Telephone: [________________________________]
Email: [________________________________]

STATE-SPECIFIC NOTES

• Statute: Conn. Gen. Stat. § 30-102 (one of the oldest dram shop acts in the U.S.).
• MANDATORY NOTICE: Written notice to the seller within 120 days of injury (180 days if incapacitated/deceased). This is a strict condition precedent.
• Notice Contents: Must include purchaser's name, date/time of sale, and injured person's details.
• DAMAGES CAP: $250,000 per accident (total for all claimants from one incident).
• SHORTENED STATUTE OF LIMITATIONS: One year from the act or omission.
• No Contributory Negligence Defense: Traditional defenses like contributory negligence and assumption of risk are generally not defenses to a statutory dram shop action.
• Negligence Bar for Adults: The statute bars negligence claims against sellers for sales to persons 21 or older; negligence claims remain available for sales to minors.
• Social Host Liability: No standalone social host liability statute, but criminal and civil liability may exist for furnishing alcohol to underage persons (§§ 30-86(b)(2) and 30-89a).
• "Just Damages": The statute uses the term "just damages," which courts have interpreted to include compensation for injuries proximately caused by the sale.

SOURCES AND REFERENCES

• Conn. Gen. Stat. § 30-102 (Dram Shop Act)
• Conn. Gen. Stat. § 30-86(b)(2) (Sale to Minors)
• Conn. Gen. Stat. § 30-89a (Social Host - Minors)