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Case Citations [i] (Spring 2026)

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                           THE AMERICAN


                           LAW INSTITUTE



                                   Spring 2026 Citations



                                   AGENCY



                              CHAPTER   5. TERMINATION

                       TOPIC  1. TERMINATION OF AUTHORITY

 TITLE  A. INFERRED   FROM   ORIGINAL   MANIFESTATION IN LIGHT OF SUBSEQUENT
                                        EVENTS

§ 106. Accomplishment of Authorized Act

Conn.2025. Cit. in diss. op. Homeowners who discovered that their homeowners' insurance policy had
not been renewed shortly after their home had been destroyed in an accidental fire sued insurance broker
and brokerage firm, alleging that defendants negligently failed to inform plaintiffs that their insurer had
declined to renew their homeowners' insurance policy. The trial court granted defendants' motion for
summary judgment, finding that, under Connecticut law, insurance agents owed no continuing legal duty
to their clients after the procurement of insurance coverage. The court of appeals affirmed. This court
affirmed, holding that there were no exceptional circumstances that would impose a duty on defendants
to inform plaintiffs that the insurer was not renewing plaintiffs' policy. The dissent argued that the
majority adhered to an outdated, bright-line rule set forth in Restatement of Agency § 106, and that
Connecticut should instead follow the modem, fact-driven approach set forth in Restatement Third of
Agency § 8.11 in determining when an agency relationship terminated and the scope of the relationship.
Deer v. National General Insurance Company, 341 A.3d 936, 955.



          CHAPTER 7.   LIABILITY  OF  PRINCIPAL   TO THIRD   PERSON;  TORTS

    TOPIC  2. LIABILITY  FOR  AUTHORIZED CONDUCT OR CONDUCT INCIDENTAL
                                       THERETO

                                 TITLE A. IN GENERAL

§ 217. Principal or Agent Has Immunities or Privileges

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         For earlier citations, see the Appendices, Supplements, or Pocket Parts, if any, that correspond to the subject matter under examination.