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 for lack of subject matter jurisdiction. It held that federal bankruptcy law implicitly preempts those claims because Congress occupied the field of penalties and sanctions for abuse of the bankruptcy process, and because state-law remedies would obstruct the federal objectives of uniformity and finality. The court further held that the difference between state and federal remedies did not avoid preemption, even though compliance with both legal regimes was theoretically possible.