SUPERIOR COURT OF THE STATE OF CONNECTICUT
JUDICIAL DISTRICT OF [COUNTY] AT [LOCATION]
DOCKET NO.: [To Be Assigned]
ESTATE OF [DECEDENT FULL LEGAL NAME], by [NAME OF EXECUTOR/ADMINISTRATOR],
Plaintiff,
v.
[PRIMARY DEFENDANT LEGAL NAME]
—and—
[ADDITIONAL DEFENDANT(S) LEGAL NAME(S)],
Defendants.
COMPLAINT
(Jury Trial Claimed)
[// GUIDANCE: This template tracks Connecticut wrongful-death pleading requirements under Conn. Gen. Stat. § 52-555 and relevant Practice Book rules. Replace bracketed placeholders, delete guidance before filing, and attach additional exhibits/schedules as needed.]
TABLE OF CONTENTS
- Definitions
- Parties
- Jurisdiction and Venue
- Factual Allegations
- Counts
- Count I – Wrongful Death – Negligence (Conn. Gen. Stat. § 52-555)
- Count II – Wrongful Death – Recklessness (Optional – Conn. Gen. Stat. § 14-295 or common-law)
- Count III – Survival Action (Conn. Gen. Stat. § 52-599) (Optional) - Damages Sought
- Prayer for Relief
- Jury Demand
- Verification
- Certification of Service
1. DEFINITIONS
For purposes of this Complaint, the following capitalized terms shall have the meanings set forth below.
1.1 “Decedent” means [DECEDENT FULL LEGAL NAME], who died on [DATE OF DEATH].
1.2 “Estate” means the probate estate of the Decedent, pending in the [NAME OF PROBATE COURT], Estate No. [PROBATE FILE NUMBER].
1.3 “Personal Representative” means [NAME OF EXECUTOR/ADMINISTRATOR], duly appointed on [DATE OF APPOINTMENT].
1.4 “Defendant” or “Defendants” means, individually and collectively, [DEFENDANT(S) LEGAL NAME(S)], together with their officers, agents, servants, employees, predecessors, successors, and assigns.
1.5 “Subject Incident” means the events of [DATE] at [LOCATION] that proximately caused the Decedent’s injuries and death.
[// GUIDANCE: Delete or add definitions to match factual scenario.]
2. PARTIES
2.1 Plaintiff Estate of [Decedent], by [Personal Representative], brings this action pursuant to Conn. Gen. Stat. § 52-555.
2.2 Defendant [Primary Defendant] is a [corporation/LLC/individual/etc.] organized under the laws of [STATE] with its principal place of business at [ADDRESS] and transacting business in Connecticut.
2.3 Defendant [Additional Defendant] is a [DESCRIPTION] with an address at [ADDRESS].
[// GUIDANCE: Add municipal-defendant statutory notice allegations (Conn. Gen. Stat. § 7-465) if suing a municipality.]
3. JURISDICTION AND VENUE
3.1 This Court has subject-matter jurisdiction pursuant to Conn. Gen. Stat. §§ 51-164s & 52-555.
3.2 Venue is proper in this Judicial District under Conn. Gen. Stat. § 51-345 because [brief venue facts].
3.3 Defendants are subject to personal jurisdiction in Connecticut under Conn. Gen. Stat. § 52-59b and the Connecticut long-arm statute as they [conduct business, committed tortious acts, etc.] within the state.
4. FACTUAL ALLEGATIONS
4.1 On [DATE], at approximately [TIME], the Decedent was [brief description of activity] at [LOCATION].
4.2 At that time and place, Defendant(s) [describe negligent or reckless acts/omissions].
4.3 As a direct and proximate result of Defendant(s)’ conduct, the Decedent sustained severe injuries causing conscious pain and suffering until death on [DATE].
4.4 Plaintiff provided all statutory notices and has otherwise satisfied all conditions precedent to suit.
4.5 The action is brought within two (2) years of Decedent’s death and within five (5) years of the underlying act or omission, as required by Conn. Gen. Stat. § 52-555.
5. COUNTS
COUNT I
Wrongful Death – Negligence
(Conn. Gen. Stat. § 52-555)
5.1 Plaintiff realleges ¶¶ 1 through 4.5.
5.2 Defendant owed the Decedent a duty of reasonable care [identify duty].
5.3 Defendant breached that duty by [specific negligent acts/omissions].
5.4 Defendant’s breach was the direct and proximate cause of the Decedent’s fatal injuries.
5.5 Under Conn. Gen. Stat. § 52-555, Plaintiff seeks all damages recoverable by law, including but not limited to:
a. Decedent’s loss of capacity to carry on and enjoy life;
b. Decedent’s conscious pain and suffering;
c. Loss of earning capacity;
d. Reasonable medical, hospital, and nursing expenses;
e. Funeral and burial expenses; and
f. Pre- and post-judgment interest as allowed by law.
COUNT II
Wrongful Death – Recklessness
(Optional – Use if facts support; consider double/treble-damages statutes)
5.6 Plaintiff realleges ¶¶ 1 through 4.5.
5.7 Defendant’s conduct was in reckless disregard of the safety and rights of others, in that Defendant [state reckless conduct].
5.8 Pursuant to Conn. Gen. Stat. § 14-295 and/or common-law recklessness, Plaintiff seeks punitive, exemplary, and/or double or treble damages, in an amount to be determined at trial, plus costs and reasonable attorneys’ fees.
COUNT III
Survival Action
(Conn. Gen. Stat. § 52-599) (Optional)
5.9 Plaintiff realleges ¶¶ 1 through 4.5.
5.10 Decedent had viable personal injury claims at the time of death that survive to the Estate pursuant to Conn. Gen. Stat. § 52-599.
5.11 Plaintiff seeks recovery of all damages Decedent could have recovered had death not ensued, including pre-death lost wages, property damage, and other special damages.
[// GUIDANCE: Retain Count III only if separate personal-injury claims are appropriate. Otherwise rely solely on § 52-555.]
6. DAMAGES SOUGHT
6.1 Plaintiff claims money damages exceeding $[THRESHOLD], exclusive of interest and costs.
6.2 Plaintiff further claims:
a. Statutory interest under Conn. Gen. Stat. § 37-3b;
b. Costs as taxed by the Clerk;
c. Any statutorily authorized punitive or exemplary damages; and
d. Such other relief this Court deems just and proper.
[// GUIDANCE: Connecticut imposes no general statutory cap on wrongful-death damages; remove or modify if a special-statute cap (e.g., medical-malpractice qualified charitable hospital) applies.]
7. PRAYER FOR RELIEF
WHEREFORE, Plaintiff respectfully requests that the Court enter judgment in favor of the Estate and against each Defendant, jointly and severally, in an amount to be proven at trial, together with:
- Compensatory damages as permitted by Conn. Gen. Stat. § 52-555;
- Punitive, exemplary, double, or treble damages where allowed by law;
- Pre-judgment and post-judgment interest;
- Costs of suit and reasonable attorneys’ fees as allowed; and
- All other and further relief the Court deems just and equitable.
8. JURY DEMAND
Plaintiff hereby demands a trial by jury on all issues so triable as of right pursuant to Conn. Gen. Stat. § 52-215 and Practice Book § 42-1.
9. VERIFICATION
I, [NAME OF PERSONAL REPRESENTATIVE], being duly sworn, state that I am the duly appointed [Executor/Administrator] of the Estate of [Decedent] and that I have read the foregoing Complaint, know the contents thereof, and that the same is true to the best of my knowledge, information, and belief.
Date: ___ day of __, 20___
[NAME OF PERSONAL REPRESENTATIVE]
[Title], Estate of [Decedent]
Subscribed and sworn before me on this ___ day of _, 20.
Notary Public
My Commission Expires: _____
[// GUIDANCE: Connecticut permits unsworn “Civil Certification” under Practice Book § 17-92 if preferred.]
10. CERTIFICATION OF SERVICE
I hereby certify that a copy of the foregoing Complaint was or will be mailed, delivered, or electronically served on all counsel and pro se parties of record on this ___ day of _, 20, in accordance with Practice Book §§ 10-12 and 10-13.
[ATTORNEY NAME], Esq.
Attorney for Plaintiff
Juris No.: [####]
Firm: [LAW FIRM NAME]
Address: [ADDRESS]
Phone: [PHONE]
Email: [EMAIL]
[// GUIDANCE:
- Attach a Civil Summons (JD-CV-1) when filing.
- Review CT Practice Book §§ 4-1–1 et seq. for electronic-filing formatting.
- If Defendant is a state agency, include notice and authorization allegations per Conn. Gen. Stat. § 4-160.
- For municipal defendants, serve the clerk and mayor (or equivalent) under Conn. Gen. Stat. § 7-101a.
- Confirm statute-of-limitations calculations—action must be filed within two (2) years of death AND five (5) years of the wrongful act/omission (§ 52-555).
- Use separate Count for spousal loss-of-consortium if warranted; spouse sues individually, not through Estate.
- Update caption if multiple plaintiffs/estates.
]