Supreme Court of Connecticut
Snell v. Norwalk Yellow Cab, Inc.
August 13, 2019
Summary
Justice Ecker concurs in the majority's reasoning and result but argues that Connecticut's superseding-cause doctrine remains unnecessarily complex and should be simplified. The concurrence identifies scope of the risk, substantial-factor causation, and the possible equivalence of superseding cause and sole proximate cause as foundations for future doctrinal development. It also cautions against addressing issues not presented concerning an unusual apportionment scenario and emphasizes that model jury instructions should be verified for accuracy. Because this is a concurrence, it states no independent holding.