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 federal bankruptcy law implicitly preempts those claims because Congress occupied the field of sanctions and remedies for bankruptcy-process abuse and because state-law actions would obstruct the federal objectives of uniformity and finality. The court also held that the claims were not expressly preempted, but that impossibility of dual compliance was unnecessary because obstacle preemption applied.