Supreme Court of Connecticut
Metcalf v. Fitzgerald
September 3, 2019333 Conn. 1
Summary
The court affirmed dismissal of the plaintiff’s state-law vexatious litigation and CUTPA claims arising from conduct in a bankruptcy proceeding. It held that the claims were preempted because federal bankruptcy law occupies the field of sanctions and remedies for abuse of the bankruptcy process, and because state-law remedies would obstruct Congress’s objectives of uniformity and finality. The court also concluded that the claims were not expressly preempted, but were impliedly preempted under both field and obstacle preemption principles.