Liljedahl Brothers, Inc. v. James A. Grigsby

Summary

The Supreme Court of Connecticut affirmed a trial court judgment striking a contractor's two-count complaint seeking the unpaid balance for home improvements performed under an oral agreement. The court held that General Statutes § 20-429(a), requiring a home improvement contract to be in writing, bars recovery on both an implied-in-fact contract theory and a quasi contract/unjust enrichment theory absent proof of homeowner bad faith, applying its dispositive precedent in Barrett Builders v. Miller. It also rejected the plaintiff's procedural claim that the motion to strike was a fatally defective 'speaking motion,' reasoning that an extraneous factual allegation relevant to only one argument does not prevent the court from considering the remaining arguments on the merits. Justice Shea, joined by Justice Callahan, dissented, restating his Barrett Builders position that the statute imposes an inequitable forfeiture on tradesmen.