Spiotti v. Clark

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Spiotti v. Clarke

BRYAN SPIOTTI v. WENDY CLARKE ET AL.
(AC 47397)
BRYAN SPIOTTI v. ANDREW WIELBLAD
(AC 47399)
Cradle, C. J., and Seeley and Bishop, Js.

Syllabus

The plaintiff in each of two cases, a police officer, appealed from the trial
court’s judgments granting in part a motion to strike by the defendants in
the first case and granting a motion to strike by the defendant in the second
case. The plaintiff alleged in his operative complaints that B, a dancer
employed at R Co., an adult entertainment establishment, was served intox-
icating liquors while on the premises of R Co. despite the fact that she was
already noticeably intoxicated and that B’s intoxicated behavior caused
personal injuries to the plaintiff, who had been called to R Co. due to B’s
disruptive behavior. The plaintiff claimed, inter alia, that the court improp-
erly granted the motions to strike as to the counts alleging reckless service
of alcohol on the ground that he failed to plead the necessary elements of
that cause of action. Held:

The trial court improperly granted the motion to strike in the first action
as to the count of the operative complaint against the defendant V Co.
alleging liability under the Dram Shop Act (§ 30-102) on the ground that the
plaintiff failed to provide timely statutory notice to V Co., as, in light of
Governor Ned Lamont’s Executive Order No. 7G that temporarily suspended
statutory deadlines related to service of process, the plaintiff provided timely
notice to V Co.

The trial court improperly struck the reckless service of alcohol counts in
both actions on the ground that the plaintiff failed to allege sufficient facts
to support the claims against the defendants because the allegations in the
operative complaints did not rise beyond ordinary negligence, as, taking as
true the factual allegations in the operative complaints and construing them
in the manner most favorable to sustaining their legal sufficiency, this court
concluded that the alleged conscious and intentional disregard of the sub-
stantial risk of serving B alcohol while she was intoxicated in favor of
increased profits demonstrated wanton and reckless conduct that, if proven,
was legally sufficient to support a cause of action for reckless service
of alcohol.

The trial court improperly determined that the reckless service of alcohol
counts in both actions were barred by the firefighter’s rule, which provides
generally that a firefighter or police officer who enters private property in
the exercise of his or her duties generally cannot bring a civil action against
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Spiotti v. Clarke
the property owner for injuries sustained as the result of a defect in the
premises, as the reckless service of alcohol counts of the operative com-
plaints did not allege any dangerous or defective conditions on the premises
but, rather, alleged recklessness in serving B alcohol in pursuit of profits
despite the fact that she already was intoxicated, and, accordingly, those
counts did not sound in premises liability and were therefore not barred
by the firefighter’s rule.

The trial court properly struck the negligent security counts of the operative
complaints in both actions, as such counts sounded in premises liability
and, thus, were barred by the firefighter’s rule.

The trial court improperly struck the negligent supervision claims against
the defendants in both actions on the ground that such claims were premised
on the service of alcohol to an intoxicated person and, as such, were barred
by the Dram Shop Act, as the allegations in the negligent supervision counts
of the operative complaints, when construed in the manner most favorable
to sustaining their legal sufficiency, included allegations outside the scope
of the Dram Shop Act and the counts therefore should not have been stricken.

The trial court improperly determined, in the alternative, that the allegations
in the negligent supervision counts of the operative complaints in both
actions were inadequate to state such a cause of action, as, when the
complaints were construed broadly, realistically, and in the manner most
favorable to sustaining their legal sufficiency, considering the facts necessar-
ily implied from the allegations, including the allegation that the defendants
had a duty to monitor B and to remove her from R Co.’s premises for
showing signs of aggressiveness, the allegations were sufficient to set forth
a cause of action for negligent supervision.
Argued June 3—officially released October 14, 2025

Procedural History

Action, in each case, to recover damages for personal
injuries sustained as a result of the defendants’ alleged
negligence, and for other relief, brought to the Superior
Court in the judicial district of Waterbury, where the
court, Pierson, J., granted the motion to intervene as
a plaintiff in the first case filed by the town of Wolcott;
thereafter, the court, D’Andrea, J., granted in part the
motion to strike filed by the defendants in the first case
and granted the motion to strike filed by the defendant
in the second case and rendered judgment thereon,
from which the plaintiff in each case appealed to this
court. Reversed in part; further proceedings.
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Spiotti v. Clarke

Andrew S. Marcucci, with whom was Robert C.
Lubus, for the appellant (plaintiff in each case).
Ron J. Houde, Jr., for the appellees (named defen-
dant et al. in Docket No. AC 47397 and defendant in
Docket No. AC 47399).
Opinion

BISHOP, J. In these consolidated appeals, the plain-
tiff,1 Bryan Spiotti, appeals from the judgments of the
trial court granting, in part, the motions of the defen-
dants2 Wendy Clarke, doing business as Rockstar Caba-
ret; W Ventures, LLC (Ventures); and Andrew Wielblad
to strike the operative complaints in the two underlying
actions. On appeal, the plaintiff claims that the trial
court improperly granted the motions to strike as to
(1) the count against Ventures alleging liability under
the Dram Shop Act, General Statutes § 30-102, due to
the plaintiff’s failure to provide timely statutory notice
of that claim, (2) the reckless service of alcohol counts
against the defendants (a) for the plaintiff’s failure to
plead the necessary elements of that cause of action
and (b) because the firefighter’s rule barred those
counts, (3) the negligent security counts against the
defendants on the grounds that they were barred by
the firefighter’s rule, and (4) the negligent supervision
counts against the defendants on the grounds that (a)
the Dram Shop Act barred those counts and (b) the
allegations were insufficient to set forth a cause of
action for negligent supervision. For the reasons that
follow, we reverse the judgments of the trial court only
1
The intervening plaintiff in the underlying action in Docket No. AC 47397,
the town of Wolcott, did not participate in this appeal.
2
The complaint also named M Properties, LLC, as a defendant in the
underlying action in Docket No. AC 47397. In his appellate brief, the plaintiff
states that he is no longer pursuing claims against M Properties, LLC, and
he does not raise any claims on appeal as to M Properties, LLC. Accordingly,
we refer in this opinion only to Clarke, doing business as Rockstar Cabaret;
W Ventures, LLC; and Wielblad as the defendants.
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with respect to the granting of the motions to strike as
to the Dram Shop Act count against Ventures and as
to both the reckless service of alcohol and the negligent
supervision counts against the defendants. Accordingly,
we reverse in part the judgments of the trial court.
These consolidated appeals arise from two underly-
ing actions brought by the plaintiff with respect to an
incident that was alleged to have occurred at an adult
entertainment establishment in Wolcott known as the
Rockstar Cabaret (Rockstar). In essence, the plaintiff
alleged in his operative complaints that Raven Booker,
a dancer employed at Rockstar, was served intoxicating
liquors while on the premises of Rockstar despite the
fact that she was already noticeably intoxicated and,
in the early morning hours of March 6, 2020, Booker’s
intoxicated behavior caused personal injuries to the
plaintiff, an officer of the Wolcott Police Department,
who had been called to Rockstar due to Booker’s disrup-
tive behavior.
The plaintiff’s operative complaint in Docket No. CV-
XX-XXXXXXX-S (2021 action), dated January 19, 2022, was
brought against Clarke, doing business as Rockstar,
and Ventures, the owner and backer of Rockstar.3 The
operative complaint sets forth the following four dis-
tinct causes of action: (1) count one against Clarke,
doing business as Rockstar, and count five against Ven-
tures are based on the Dram Shop Act; (2) count two
against Clarke, doing business as Rockstar, and count
six against Ventures allege reckless service of alcohol;
(3) count three against Clarke, doing business as Rock-
star, and count seven against Ventures assert claims
based on negligent security; and (4) count four against
3
This complaint also set forth claims against M Properties, LLC, namely,
a violation of the Dram Shop Act (count nine), reckless service of alcohol
(count ten), negligent security (count eleven), and negligent supervision
(count twelve). See footnote 2 of this opinion.
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Clarke, doing business as Rockstar, and count eight
against Ventures allege negligent supervision.
On August 29, 2022, Clarke, doing business as Rock-
star, and Ventures filed a motion to strike the counts
of the complaint against them.4 Specifically, they argued
that (1) the Dram Shop Act counts were barred because
the plaintiff failed to provide them with timely statutory
notice of those claims; (2) the reckless service of alco-
hol counts were (a) legally insufficient because they
did not allege recklessness but only mere negligence
and (b) otherwise barred by the firefighter’s rule; (3) the
counts sounding in negligent security (a) were barred
by the firefighter’s rule and (b) failed sufficiently to
plead a duty owed by the defendants; and (4) the counts
alleging negligent supervision (a) were simply a reitera-
tion of the allegations under the Dram Shop Act, which
constitutes the exclusive remedy, and (b) were legally
insufficient.
In Docket No. CV-XX-XXXXXXX-S (2022 action), the
plaintiff brought an amended complaint, dated Decem-
ber 7, 2022, against Wielblad, an owner of Rockstar,
personally. That operative complaint alleged against
Wielblad a claim based on the Dram Shop Act (count
one); reckless service of alcohol (count two); negligent
security (count three); and negligent supervision (count
four). Wielblad filed a motion to strike the complaint
against him in its entirety, raising arguments similar to
those presented in the motion to strike in the 2021
action.
In the trial court, these two complaints and motions
to strike followed parallel tracks but were not consoli-
dated. On January 26, 2024, the court ruled on the
motions to strike in the 2021 action and the 2022 action
using similar reasoning. The court granted the motion
4
M Properties, LLC, also participated in the motion to strike and the court
granted that motion as to all counts against M Properties, LLC.
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Spiotti v. Clarke

to strike in the 2021 action as to eleven counts of the
operative complaint, leaving only count one alleging
Dram Shop Act liability against Clarke, doing business
as Rockstar. In the 2022 action, the court granted the
motion to strike as to all four counts of the operative
complaint. These appeals followed.5 The plaintiff filed
a motion to consolidate the two appeals, which this
court granted.

Before addressing the plaintiff’s claims, we set forth
the following standard of review concerning a motion
to strike. ‘‘Because a motion to strike challenges the
legal sufficiency of a pleading and, consequently, requires
no factual findings by the trial court, our review of the
court’s ruling on the [motion to strike] is plenary. . . .
We take the facts to be those alleged in the complaint
that has been stricken and we construe the complaint
in the manner most favorable to sustaining its legal
sufficiency. . . . Thus, [i]f facts provable in the com-
plaint would support a cause of action, the motion to
strike must be denied. . . . Moreover, we note that
[w]hat is necessarily implied [in an allegation] need
not be expressly alleged. . . . It is fundamental that in
determining the sufficiency of a complaint challenged
5
On the date that these appeals originally were filed, the trial court had
not yet rendered a judgment on the stricken counts, and, in the 2021 action,
there remained a count outstanding against Clarke, doing business as Rock-
star. The plaintiff filed a motion pursuant to Practice Book § 61-4 (b) in the
2021 action seeking permission to file an immediate appeal as to the order
striking three of the counts of the complaint against Clarke, doing business
as Rockstar. The trial court granted the plaintiff’s § 61-4 motion on April 1,
2024. The plaintiff filed a further § 61-4 motion with this court. On April 29,
2024, this court granted the motion on the condition that judgment be
rendered on the stricken counts of both underlying complaints on or before
May 6, 2024, and both appeals be amended accordingly. See Practice Book
§§ 10-44 and 61-9; Breen v. Phelps, 186 Conn. 86, 89, 439 A.2d 1066 (1982);
Pellecchia v. Connecticut Light & Power Co., 139 Conn. App. 88, 90, 54 A.3d
658 (2012), cert. denied, 307 Conn. 950, 60 A.3d 740 (2013). The trial court
rendered judgment on the stricken counts in both actions on May 3, 2024,
and the plaintiff amended both appeals accordingly.
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by a defendant’s motion to strike, all well-pleaded facts
and those facts necessarily implied from the allegations
are taken as admitted. . . . Indeed, pleadings must be
construed broadly and realistically, rather than nar-
rowly and technically.’’ (Emphasis in original; internal
quotation marks omitted.) Kumah v. Brown, 127 Conn.
App. 254, 259, 14 A.3d 1012 (2011), aff’d, 307 Conn. 620,
58 A.3d 247 (2013).
I
The plaintiff first claims that the court improperly
granted the motion to strike as to the count of the
operative complaint in the 2021 action against Ventures
alleging liability under the Dram Shop Act on the ground
that he failed to provide timely statutory notice.6 We
agree.
The Dram Shop Act permits an action against any
person who sells liquor to an intoxicated purchaser
who, as a result of such intoxication, causes injuries
to a third person, ‘‘provided the aggrieved person . . .
shall give written notice to such seller of such person’s
. . . intention to bring an action under this section.
Such notice shall be given . . . within one hundred
twenty days of the occurrence of such injury to person
or property . . . . Such notice shall specify the time,
the date and the person to whom such sale was made,
the name and address of the person injured or whose
property was damaged, and the time, date and place
where the injury to person or property occurred.’’ Gen-
eral Statutes § 30-102.
The 120 day notice requirement of the Dram Shop
Act is a condition precedent to maintaining a cause of
action alleging a violation of the Dram Shop Act; the
In ruling on the motions to strike, the court noted that, although the
6

notice requirement under § 30-102 is properly addressed in a motion to
dismiss, the plaintiff had agreed on the record that the court could resolve
the issue in the context of the defendants’ motion to strike.
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failure to file timely notice pursuant to § 30-102 deprives
the trial court of subject matter jurisdiction. See Daven-
port v. Quinn, 53 Conn. App. 282, 292–93, 730 A.2d 1184
(1999). Our review of the issue of whether the trial
court properly determined that the plaintiff’s statutory
notice under § 30-102 was defective is plenary. See
id., 286–87.
Attached to the original complaint in the 2021 action
is a return of service, dated November 9, 2020, stating
that service was made on Clarke and provided notice
of an intent to bring an action pursuant to the Dram
Shop Act. There is also a return of service in the file
dated March 9, 2021, in which the state marshal indi-
cates that service was made on, among others, Ven-
tures. In determining whether notice was given within
120 days, we turn to Governor Ned Lamont’s pandemic
related Executive Orders concerning the tolling of statu-
tory time limits. Governor Lamont’s Executive Order
No. 7G, effective March 19, 2020, suspended the opera-
bility of statutory time limits and requirements regard-
ing service of process until that suspension was lifted
on March 1, 2021, by Governor Lamont’s Executive
Order No. 10A.7
The court determined that because the November 9,
2020 notice letter was addressed only to Clarke, whom
7
Executive Order No. 7G provides in relevant part: ‘‘I hereby suspend,
for the duration of this public health and civil preparedness emergency,
unless earlier modified or terminated by me, all statutory . . . (2) time
requirements, statutes of limitation or other limitations or deadlines relating
to service of process, court proceedings or court filings . . . . Unless other-
wise specified herein, this order shall take effect immediately and shall
remain in effect for the duration of the public health and civil preparedness
emergency, unless earlier modified by me.’’ Executive Order No. 7G (March
19, 2020).
Executive Order No. 10A provides in relevant part: ‘‘[T]he provisions of
Executive Order No. 7G, Section 2, dated March 19, 2020 . . . as they relate
to the following, shall expire on March 1, 2021 . . . a. all statutory time
requirements, statutes of limitation or other limitations or deadlines relating
to service of process, court proceedings or court filings in civil matters
. . . .’’ Executive Order No. 10A (March 1, 2021).
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Spiotti v. Clarke

the court determined had received timely notice, and
because ‘‘§ 30-102 required that ‘the aggrieved person
or persons shall give written notice to such seller of
such person’s or persons’ intention to bring an action
under this section,’ ’’ then ‘‘[t]he plaintiff has not pro-
vided sufficient legal support for this court to conclude
that giving notice to [Clarke], Permittee, personally,
with her claimed mailing address at [Ventures in Wol-
cott], constitutes proper statutory notice to [Ventures]
. . . .’’ The court concluded that Ventures did not
receive timely statutory notice and struck that count
of the operative complaint in the 2021 action.
Applying the timing of Executive Order No. 7G and
its recission to the present case leads us to a different
result than that reached by the trial court. The record
reflects a return of service dated March 9, 2021, indicat-
ing that Ventures had been served with the complaint by
that date. The complaint contained all of the plaintiff’s
assertions against Ventures with the particularity
required by the Dram Shop Act, and there is no claim
on appeal that the substance of the notice was insuffi-
cient or that such notice could not be appended to a
complaint.
The 120 day notice requirement of the Dram Shop
Act was suspended as a result of Governor Lamont’s
Executive Order No. 7G, effective March 19, 2020, and
that suspension subsequently was lifted on March 1,
2021, by Governor Lamont’s Executive Order No. 10A.
The injury was alleged to have occurred on March 6,
2020, thirteen days before the effective date of Execu-
tive Order No. 7G. Notice was given to Ventures on
March 9, 2021, eight days after the suspension of the 120
day notice requirement had been lifted.8 Accordingly,
notice to Ventures was timely provided within 120 days
8
We note that none of the parties in this matter has argued that Executive
Order No. 7G or its termination is inapplicable to the present case.
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pursuant to § 30-102 and, therefore, we conclude that
the court improperly struck the Dram Shop Act count
(count five of the operative complaint in the 2021
action) against Ventures.
II
The plaintiff next claims that the court improperly
struck the reckless service of alcohol counts against
the defendants in that it improperly determined that
(1) the operative complaints failed to sufficiently plead
the necessary elements of that cause of action and (2)
the firefighter’s rule applied so as to bar those claims.
We agree with the plaintiff.
A
In ruling on the motions to strike, the court reasoned,
similarly, but in two separate decisions, that the reck-
less service of alcohol counts of the operative com-
plaints failed to allege sufficient facts to support the
claims against the defendants in that the allegations in
the operative complaints did not rise beyond ordinary
negligence. Our analysis leads us to a different conclu-
sion.
‘‘The interpretation of pleadings is . . . a question
of law for the court . . . [over which] [o]ur review
. . . is plenary.’’ (Internal quotation marks omitted.)
Carrico v. Mill Rock Leasing, LLC, 199 Conn. App. 252,
261, 235 A.3d 626 (2020). ‘‘In order to prove that a sale
of intoxicating liquor was made in a wilful, wanton and
reckless manner, the plaintiff must demonstrate that
the defendants acted in a manner that tended to take
on the aspect of highly unreasonable conduct, involving
an extreme departure from ordinary care, in a situation
where a high degree of danger is apparent.’’ (Internal
quotation marks omitted.) Coble v. Maloney, 34 Conn.
App. 655, 661, 643 A.2d 277 (1994). The elements of
reckless service of alcohol are: (1) intoxication, (2)
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Spiotti v. Clarke

that was readily apparent, and (3) that the defendant
continued to serve alcoholic beverages despite obvious
intoxication. See Futterleib v. Mr. Happy’s, Inc., 16
Conn. App. 497, 509–10, 548 A.2d 728 (1988).
‘‘Recklessness requires a conscious choice of a
course of action either with knowledge of the serious
danger to others involved in it or with knowledge of
facts which would disclose this danger to any reason-
able man, and the actor must recognize that his conduct
involves a risk substantially greater . . . than that
which is necessary to make his conduct negligent.’’
(Internal quotation marks omitted.) Matthiessen v.
Vanech, 266 Conn. 822, 832, 836 A.2d 394 (2003). ‘‘The
reason that intentional and reckless misconduct are
treated the same is that the difference between the two
in a conceptual sense is microscopic. Wanton miscon-
duct is more than negligence, more than gross negli-
gence. It is such conduct as indicates a reckless disre-
gard of the just rights or safety of others or of the
consequences of action. Wilful misconduct is inten-
tional misconduct, and wanton misconduct is reckless
misconduct, which is the equivalent of wilful miscon-
duct.’’ (Internal quotation marks omitted.) Futterleib v.
Mr. Happy’s, Inc., supra, 16 Conn. App. 509–10.
Contrary to the trial court’s determination, we con-
clude that the allegations in the reckless service of
alcohol counts, if proven, show a wanton disregard for
safety. Specifically, in those counts the plaintiff alleged
the following: ‘‘[I]t is common practice at Rockstar for
exotic dancers to mingle with patrons at the bar and
for the patrons to buy drinks for the dancers, as these
personal interactions encourage the patrons to spend
more money at the establishment in the form of private
dances or lap dances and alcohol, which consequently
accrues to the monetary benefit of both the dancers
and the defendant[s] . . . [who] not only tolerated but
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openly encouraged this practice.’’9 Additionally, the
counts alleged that the defendants ‘‘therefore had an
incentive to consciously disregard the risk of overserv-
ing [Booker] in the pursuit of profit, and they did in
fact consciously disregard [that] risk on March 6, 2020.’’
The plaintiff further alleged that the defendants, their
agents, servants, and/or employees knew or should have
known that ‘‘serving an intoxicated person on the prem-
ises constituted a substantial risk to the safety of its
patrons and to the public’’ and that the wrongful con-
duct of the defendants, their agents, servants, and/or
employees ‘‘indicates a conscious, wanton, wilful, and/
or deliberate disregard of the rights and safety of [the
plaintiff] and was reckless, exhibiting highly unreason-
able conduct involving an extreme departure from ordi-
nary care in a situation where a high degree of danger
is, or should have been, apparent.’’
Taking as true the factual allegations in the operative
complaints and construing them in the manner most
favorable to sustaining legal sufficiency; see Kumah v.
Brown, supra, 127 Conn. App. 259; we conclude that
the alleged conscious and intentional disregard of the
substantial risk of serving Booker alcohol while she was
intoxicated in favor of increased profits demonstrates
wanton and reckless conduct that, if proven, is legally
sufficient to support a cause of action for reckless ser-
vice of alcohol.
B
The plaintiff also argues that the court improperly
determined that the reckless service of alcohol counts
9
The reckless service of alcohol count against Wielblad further alleged
that, prior to the date of the incident, Wielblad knew that Booker had been
reprimanded by staff at Rockstar for bringing alcohol into the establishment
when arriving for her shift and had previously been fired for such actions
and that Wielblad rehired her due to a shortage of dancers and/or because
she was a significant source of revenue for Wielblad and/or Rockstar. We
note that we consider these allegations only as to Wielblad and that the
reckless service counts against Ventures and Clarke doing business as Rock-
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Spiotti v. Clarke

sound in premises liability and, therefore, are barred
by the firefighter’s rule. We agree.
As previously noted, ‘‘[t]he interpretation of plead-
ings is . . . a question of law for the court . . . [over
which] [o]ur review . . . is plenary.’’ (Internal quota-
tion marks omitted.) Carrico v. Mill Rock Leasing, LLC,
supra, 199 Conn. App. 261.
‘‘The common-law firefighter’s rule provides, in gen-
eral terms, that a firefighter or police officer who enters
private property in the exercise of his duties occupies
the status of a licensee and, therefore, is owed a duty
of care by the property owner that is less than that
owed to an ordinary invitee. . . . Thus, under the fire-
fighter’s rule, the landowner generally owes the fire-
fighter or police officer injured on his property only
the duty not to injure him wilfully or wantonly . . . .’’
(Citation omitted; internal quotation marks omitted.)
Levandoski v. Cone, 267 Conn. 651, 653–54, 841 A.2d 208
(2004). In other words, the firefighter’s rule generally
provides ‘‘that a firefighter or police officer who enters
private property in the exercise of his or her duties
generally cannot bring a civil action against the property
owner for injuries sustained as the result of a defect
in the premises.’’ Sepega v. DeLaura, 326 Conn. 788,
789, 167 A.3d 916 (2017). ‘‘[T]he firefighter’s rule does
not extend beyond claims of premises liability.’’ Lund
v. Milford Hospital, Inc., 326 Conn. 846, 860, 168 A.3d
479 (2017); see also Sepega v. DeLaura, supra, 789
(holding that firefighter’s rule should not be extended
beyond claims of premises liability); Levandoski v.
Cone, supra, 661 (firefighter’s rule is confined to claims
of premises liability).
In Sepega v. DeLaura, supra, 326 Conn. 788, the plain-
tiff, a municipal police officer, brought suit against the
star are sufficient despite not containing the additional allegations as made
against Wielblad.
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defendant alleging injuries resulting from the defen-
dant’s negligence in creating conditions wherein the
plaintiff was mandated to kick in the door to the defen-
dant’s home. Id., 790. Our Supreme Court concluded
that because the claim sounded in ordinary negligence
and not premises liability relating to dangerous or defec-
tive conditions on the premises, the trial court improp-
erly granted the defendant’s motion to strike on the
basis that the claim was barred by the firefighter’s rule.
Id., 790–815. In so deciding, our Supreme Court held that
‘‘the firefighter’s rule should not be extended beyond
claims of premises liability . . . .’’ Id., 789.
In Lund v. Milford Hospital, Inc., supra, 326 Conn.
846, a Connecticut state trooper brought an action
against Milford Hospital, Inc., for injuries sustained
while subduing an emotionally disturbed patient, alleg-
ing that the hospital was negligent in failing to supervise
or restrain the patient properly; failing to provide for
adequate security in the area where foreseeably danger-
ous patients were held; allowing the patient, who was
known to be dangerous, to go to the bathroom unre-
strained and unaccompanied; and failing to train its staff
properly. Id., 848. The trial court granted the defendant’s
motion to strike, determining that the complaint was
barred by the firefighter’s rule. Id., 849. Our Supreme
Court reversed, reasoning that the plaintiff’s complaint
sounded in negligence and that, in light of Sepega, the
firefighter’s rule does not extend beyond claims of
premises liability. Id., 859–60.
As in Lund and Sepega, the reckless service of alcohol
counts of the operative complaints in the present case
do not allege any dangerous or defective conditions on
the premises. Rather, those counts alleged recklessness
in serving Booker alcohol in pursuit of profits despite
the fact that she already was intoxicated. Accordingly,
those counts are not barred by the firefighter’s rule
because they do not sound in premises liability.
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For the foregoing reasons, as detailed in part II A and
B of this opinion, we conclude that the court improperly
struck the reckless service of alcohol counts against
the defendants.
III
The plaintiff next claims that the court improperly
struck the negligent security counts of the operative
complaints against the defendants on the ground that
they were barred by the firefighter’s rule.10 We disagree.

The issue before us is whether the negligent security
counts sound in premises liability and, thus, are barred
by the firefighter’s rule, or whether they sound in ordi-
nary negligence and, therefore, are not barred by the
firefighter’s rule. See, e.g., Sepega v. DeLaura, supra,
326 Conn. 789 (holding that firefighter’s rule does not
extend beyond claims of premises liability).

As previously noted, because our review of this claim
involves the interpretation of pleadings, a legal determi-
nation, our review is plenary. See Carrico v. Mill Rock
Leasing, LLC, supra, 199 Conn. App. 261. ‘‘[W]e long
have eschewed the notion that pleadings should be read
in a hypertechnical manner. Rather, [t]he modern trend,
which is followed in Connecticut, is to construe plead-
ings broadly and realistically, rather than narrowly and
technically. . . . [T]he complaint must be read in its
entirety in such a way as to give effect to the pleading
with reference to the general theory upon which it pro-
ceeded, and do substantial justice between the par-
ties. . . .
10
The plaintiff also argues that the court improperly determined that he
failed to allege facts establishing a duty, a breach of that duty, and proximate
cause with respect to the negligent security counts of the operative com-
plaints. Because the negligent security counts are barred by the firefighter’s
rule regardless of whether they were sufficiently pleaded, we need not
address this additional argument.
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‘‘[T]he essential elements of a cause of action in negli-
gence are well established: duty; breach of that duty;
causation; and actual injury . . . and [t]he existence
of a duty of care is a prerequisite to a finding of negli-
gence . . . . The existence of a duty is a question of
law and only if such a duty is found to exist does
the trier of fact then determine whether the defendant
[breached] that duty in the particular situation at
hand. . . .
‘‘With respect to the element of duty in a premises
liability action, possession and control of the premises
by the defendant is dispositive. Liability for injuries
caused by defective premises . . . does not depend on
who holds legal title, but rather on who has possession
and control of the property. . . . Thus, the dispositive
issue in deciding whether a duty exists is whether the
[defendant] has any right to possession and control
of the property.’’ (Citations omitted; internal quotation
marks omitted.) Carrico v. Mill Rock Leasing, LLC,
supra, 199 Conn. App. 261–63.
In counts three and seven of the operative complaint
in the 2021 action, alleging negligent security against
Clarke, doing business as Rockstar, and Ventures, and
in count three of the operative complaint in the 2022
action, alleging negligent security against Wielblad, the
plaintiff alleges that the defendants, their agents, ser-
vants, and/or employees had a duty to provide adequate
security on the Rockstar premises and that the injuries
sustained by the plaintiff were the result of negligent
security in that: there was not enough security staff
and/or bouncers appropriate for the venue, taking into
account all of the circumstances there and then
existing; the defendants failed to hire security staff and/
or bouncers with professional security experience and
training to regulate behavior on the premises that would
otherwise prompt a police response; and the defendants
failed to provide adequate training to the security staff
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and/or bouncers to regulate behavior on the premises
that would otherwise prompt a police response.
In the case at hand, however, our analysis does not
turn on whether the defendants owed a duty of care
to the plaintiff but, instead, turns on whether these
particular counts are based on a claim of premises
liability. On the basis of our review of the operative
complaint, we conclude that this claim falls squarely
within the category of a premises liability claim.
The Supreme Court’s decision in Monk v. Temple
George Associates, LLC, 273 Conn. 108, 869 A.2d 179
(2005), aids our analysis of whether the claims in the
present case are based on the theory of premises liabil-
ity. In Monk, a nightclub patron was attacked by her
husband’s former girlfriend in a parking lot owned or
managed by the defendants. Id., 110. In reversing the
judgment of this court, our Supreme Court considered
‘‘whether the Appellate Court improperly affirmed the
decision of the trial court granting the defendants’
motion for summary judgment on the ground that it is
inconsistent with public policy to impose on parking
lot owners and managers a duty of care to business
invitees who are attacked intentionally on the premises
by assailants with whom the invitees are acquainted.’’
Id.
By describing the plaintiff patron’s status with
respect to the premises as a business invitee, our
Supreme Court framed the issue regarding the lack of
adequate security in terms of premises liability. ‘‘In the
case of a negligence action grounded upon a theory of
premises liability, the nature of the duty owed to a
plaintiff depends upon the plaintiff’s status on the prem-
ises at the time of the alleged injury. . . . A possessor
of land has a duty to an invitee to reasonably inspect
and maintain the premises in order to render them
reasonably safe. . . . In addition, the possessor of land
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must warn an invitee of dangers that the invitee could
not reasonably be expected to discover. . . . Such a
duty of care to an invitee, however, only attaches if the
defendant exercised possession and control over the
area at the time and place the injury occurred.’’ (Cita-
tions omitted; footnote omitted; internal quotation
marks omitted.) Millette v. Connecticut Post Ltd. Part-
nership, 143 Conn. App. 62, 69–70, 70 A.3d 126 (2013).
In the present case, the gravamen of the plaintiff’s
negligent security counts against the defendants is the
failure of those in possession and control of Rockstar
(Clarke, Ventures, and Wielblad), through their agents,
servants, and/or employees, to maintain the premises
in such a manner as to keep it reasonably safe. See
Sweeney v. Friends of Hammonasset, 140 Conn. App.
40, 49, 58 A.3d 293 (2013) (‘‘[a]s the plaintiff’s allegations
stem from an injury caused by a dangerous condition
on the premises, liability is dependent on possession
and control of the dangerous premises’’).
Similar to the claim of a lack of security in the parking
lot in Monk, the allegations in the negligent security
counts in the present case stem from an alleged danger-
ous condition on the premises, specifically, that of inad-
equate security. These allegations, therefore, are related
to the defendants’ alleged possession and control of
Rockstar because, without such possession and control,
the defendants owed no duty to the plaintiff. Accord-
ingly, we determine that the negligent security counts
sound in premises liability and, therefore, are barred
by the firefighter’s rule. Thus, we conclude that the
court properly granted the motions to strike as to the
negligent security counts of the operative complaints
against the defendants.11
11
The plaintiff also argues that a public function exception to the firefight-
er’s rule applies. The plaintiff cites no case law nor are we aware of any
applying a public function exception to the firefighter’s rule. Rather, in
support of his argument, the plaintiff cites to Morin v. Bell Court Condomin-
ium Assn., Inc., 223 Conn. 323, 612 A.2d 1197 (1992). In that case, a police
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IV
The plaintiff last claims that the court improperly
struck the negligent supervision claims against the
officer, who was injured when he tripped on a defective stair after responding
to a fire at the defendant condominium, brought an action for negligence
in the maintenance of the stairway. Id., 325. The jury returned a verdict for
the plaintiff, but the trial court granted the defendant’s motion to set aside
the verdict and the plaintiff appealed. Id., 326. In affirming the judgment of
this court, our Supreme Court held that there was insufficient evidence as
a matter of law to support the conclusion that the defendant had constructive
notice of the plaintiff’s presence at the time and place of the incident. Id., 325.
The plaintiff in Morin argued that ‘‘even if he failed to establish construc-
tive notice by showing a predictable pattern of prior usage, constructive
notice should be assumed because, according to § 345 (2) of the Restatement
(Second) of Torts, there is an exception to the general rule that licensees
are not afforded the implied representation of safety given to invitees when,
as here, the premises were open to the public. The exception provides that
‘[t]he liability of a possessor of land to a public officer or employee who
enters the land in the performance of his public duty, and suffers harm
because of a condition of a part of the land held open to the public, is the
same as the liability to an invitee.’ . . . 2 Restatement (Second), Torts
[§ 345 (2), pp. 226–27 (1965)].’’ (Emphasis in original.) Morin v. Bell Court
Condominium Assn., Inc., supra, 223 Conn. 334. After noting a paucity of
case law, our Supreme Court rejected the plaintiff’s argument that he should
be considered an implied invitee because he was injured in an area open
to the public because ‘‘[t]he fact that common areas of a condominium
complex are open to the various condominium owners does not establish
that they are, as a matter of law, open to the public. In situations in which
the premises have been considered open to the public, there is generally
some sort of public function or traditional business purpose being served.
Public or business functions are conspicuously absent in a private residence
such as a condominium building.’’ (Footnotes omitted.) Id., 334–35.
Significantly, Morin contains no mention of the firefighter’s rule. At the
time of the trial court’s 1990 decision in Morin, the firefighter’s rule had
not yet been extended by our Supreme Court in Furstein v. Hill, 218 Conn.
610, 590 A.2d 939 (1991), to police officers. ‘‘In Furstein v. Hill, supra, [610,
our Supreme Court] considered whether to extend the firefighter’s rule to
a police officer. . . . [In Furstein, our Supreme Court] read [Roberts v.
Rosenblatt, 146 Conn. 110, 148 A.2d 142 (1959)] as adopt[ing] the principle
expressed in the Restatement (Second) of Torts, § 345 (1), that the liability
of a possessor of land to one who enters the land only in the exercise of
a privilege, for either a public or a private purpose, and irrespective of the
possessor’s consent, is the same as the liability to a licensee. 2 Restatement
(Second), Torts [§ 345 (1), pp. 226–27 (1965)]. Furstein v. Hill, supra, 615.
We concluded that the rule applies to police officers as well as firefighters.’’
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defendants on the ground that (a) those claims were
premised on the service of alcohol to an intoxicated
person and, as such, were barred by the Dram Shop Act
and (b) the allegations, nonetheless, were insufficient
to set forth a cause of action for negligent supervision.
We agree with the plaintiff.
The operative complaints allege that the plaintiff’s
injuries were the result of the negligent supervision of
the defendants’ employees by their agents, servants,
and/or employees, in the following ways: (1) inadequate
supervision of security staff and/or bouncers thereby
causing the altercation to spiral out of control and
prompt a police response; (2) failure to properly train
their agents, servants, and/or employees to properly
monitor individuals showing signs of intoxication and/
or aggressiveness; (3) failure to adopt adequate policies
and/or procedures for monitoring individuals showing
signs of intoxication and/or aggressiveness; (4) failure
to properly train their agents, servants, and/or employ-
ees to remove individuals showing signs of intoxication
and/or aggressiveness from the premises; (5) failure to
adopt adequate policies and/or procedures for removing
individuals showing signs of intoxication and/or aggres-
siveness from the premises; (6) failure to properly
supervise the premises; (7) failure to properly and ade-
quately staff the premises; and (8) failure to provide
adequate security on the premises.
(Citation omitted; internal quotation marks omitted.) Levandoski v. Cone,
supra, 267 Conn. 659.
The firefighter’s rule is not without distinction between public and private
property. ‘‘The common-law firefighter’s rule provides, in general terms,
that a firefighter or police officer who enters private property in the exercise
of his duties occupies the status of a licensee and, therefore, is owed a duty
of care by the property owner that is less than that owed to an ordinary
invitee.’’ Id., 653–54. The operative complaints in the present case alleged
that Rockstar was owned by Clarke, Ventures, and Wielblad. Despite the
plaintiff’s argument that Rockstar was open to the public, there is no dispute
that Rockstar was privately owned.
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A
The trial court determined that the negligent supervi-
sion counts against the defendants were ‘‘clearly and
specifically related to the service of alcohol, which falls
exclusively under the scope of the Dram Shop Act.’’
Our analysis leads us to a different conclusion.
We begin with a brief discussion of the history of the
Dram Shop Act and its relationship to a common-law
negligence claim set on the same factual allegations. In
Quinnett v. Newman, 213 Conn. 343, 568 A.2d 786
(1990), overruled by Craig v. Driscoll, 262 Conn. 312,
813 A.2d 1003 (2003), our Supreme Court explained the
history of a common-law claim for negligence in the
selling of alcohol to intoxicated adults and the Dram
Shop Act as follows: ‘‘At common law there is no cause
of action based upon negligence in selling alcohol to
adults who are known to be intoxicated. While such
acts may constitute the breach of a duty owed to others,
the cause of action in a variety of factual settings has
uniformly failed for the reason that the subsequent
injury has been held to have been proximately caused
by the intervening act of the immoderate consumer
whose voluntary and imprudent consumption of the
beverage brings about intoxication and the subsequent
injury. . . . In Connecticut, as far back as 1872, it came
to be felt that the . . . common-law rule [limiting the
liability of purveyors of alcohol] was to some extent
overly harsh and should be modified by statute. . . .
The 1872 act gave a cause of action against a seller
who sold intoxicating liquor to a person who thereby
became intoxicated for any damage or injury to any
other person, or to the property of another done by the
intoxicated person in consequence of his intoxication.
Thus, this act, in situations where it was applicable,
displaced the common-law rule that the proximate
cause of intoxication was not the furnishing of the liquor
but its consumption. . . . The modern version of this
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so-called civil damage or dram shop act is . . . § 30-
102. Despite numerous amendments throughout its one
hundred twenty-nine year history, the act’s applicability
remains essentially unchanged.’’ (Citations omitted;
footnote omitted; internal quotation marks omitted.)
Quinnett v. Newman, supra, 345–47. In Quinnett, our
Supreme Court held that ‘‘we are here confronted with
a tavern seller-adult patron situation, the precise factual
circumstance contemplated by § 30-102. This being the
case, we defer to the legislative policy as it is articulated
by § 30-102 and leave the plaintiff to the remedy set
forth therein.’’ Id., 347–48.

In Craig v. Driscoll, supra, 262 Conn. 312, our
Supreme Court overruled Quinnett, holding that the
Dram Shop Act ‘‘does not occupy the field so as to
preclude a common-law action in negligence against a
purveyor of alcoholic beverages for service of alcoholic
liquor to an adult patron who, as a result of his intoxica-
tion, injures another.’’ Id., 330. Shortly after the decision
in Craig, ‘‘the legislature effectively overruled [the]
holding in that case by expressly abrogating the com-
mon-law negligence action that this court had recog-
nized. See Public Acts 2003, No. 03-91.’’ O’Dell v. Kozee,
307 Conn. 231, 265, 53 A.3d 178 (2012). Number 03-91
of the 2003 Public Acts added the following language
to the Dram Shop Act: ‘‘Such injured person shall have
no cause of action against such seller for negligence in
the sale of alcoholic liquor to a person twenty-one years
of age or older.’’ As a result, the plain language of the
Dram Shop Act eliminates the common-law negligence
causes of action allowed for by Craig and constitutes
the exclusive remedy ‘‘[i]f any person, by such person
or such person’s agent, sells any alcoholic liquor to an
intoxicated person, and such purchaser, in consequence
of such intoxication, thereafter injures the person or
property of another . . . .’’ General Statutes § 30-102.
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The question before us is whether the Dram Shop
Act bars the plaintiff’s negligent supervision claims.
‘‘Under Connecticut law, an employer may be held liable
for the negligent supervision of employees. See Gutier-
rez v. Thorne, 13 Conn. App. 493, 500, 537 A.2d 527
(1988) (recognizing independent claim of direct negli-
gence against employer who failed to exercise reason-
able care in supervising employee); Roberts v. Circuit-
Wise, Inc., 142 F. Sup[p]. 2d 211, 214 (D. Conn. 2001)
(in negligent supervision action, ‘plaintiff must plead
and prove that she suffered an injury due to the defen-
dant’s failure to supervise an employee whom the defen-
dant had [a] duty to supervise’); see also Shore v. Ston-
ington, 187 Conn. 147, 155, 444 A.2d 1379 (1982)
(liability in ‘any situation where a third party is injured
by an employer’s own negligence in failing to select an
employee fit or competent to perform the services of
employment’).’’ Seguro v. Cummiskey, 82 Conn. App.
186, 191, 844 A.2d 224 (2004).
In the present case, the negligent supervision counts
of the operative complaints largely restate the allega-
tions in the Dram Shop Act counts as to the service of
alcohol to an intoxicated person. They also contain,
however, when construed in the manner most favorable
to sustaining their legal sufficiency; see, e.g., Kumah
v. Brown, supra, 127 Conn. App. 259; allegations outside
the scope of the Dram Shop Act. The negligent supervi-
sion counts are not premised on simple negligence.
Rather, they assert distinct claims against the defen-
dants for a failure to supervise. Specifically, the Dram
Shop Act allows the seller of alcohol to be held liable
for injuries caused to a third person by a purchaser
of alcohol as a consequence of such intoxication but
provides that the injured person ‘‘shall have no cause
of action against such seller for negligence in the sale
of alcoholic liquor to a person twenty-one years of age
or older.’’ General Statutes § 30-102. By contrast, a claim
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sounding in negligent supervision pertains to an
employer’s failure to exercise reasonable care in super-
vising employees. See Seguro v. Cummiskey, supra, 82
Conn. App. 191–92. The negligent supervision counts
in the present case alleged, in part, that the defendant
employers failed to adequately supervise security staff
and bouncers in such a way that they would know
to remove from the premises an employee who was
becoming aggressive. This relates to an employer’s
response to a situation apart from any service or ingest-
ing of alcohol by a disruptive employee. Accordingly,
we conclude that because the plaintiff pleaded negligent
supervision outside the scope of the Dram Shop Act,
the related counts should not have been stricken.
B
Finally, as to the negligent supervision counts, the
plaintiff argues that the court improperly determined
that the allegations in the operative complaints were
inadequate to state such a cause of action. We agree.
The trial court determined, in the alternative, that
the negligent supervision counts against the defendants
failed to allege the necessary elements of that cause of
action. The court considered this an additional reason
to strike the negligent supervision counts of the opera-
tive complaints.
Our review of this claim involves the interpretation
of pleadings, a legal determination, over which our
review is plenary. See Carrico v. Mill Rock Leasing,
LLC, supra, 199 Conn. App. 261. ‘‘[A]n employer may
be held liable for the negligent supervision of employ-
ees. . . . [I]n [a] negligent supervision action, [a] plain-
tiff must plead and prove that [he] suffered an injury
due to the defendant’s failure to supervise an employee
whom the defendant had [a] duty to supervise . . . .
Negligence occurs where one under a duty to exercise
a certain degree of care to avoid injury to others fails
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to do so. . . . The essential elements of a cause of
action in negligence are well established: duty; breach
of that duty; causation; and actual injury.’’ (Citations
omitted; internal quotation marks omitted.) Seguro v.
Cummiskey, supra, 82 Conn. App. 191–92.

The operative complaints allege that Booker was an
employee of Rockstar; that the defendants, their agents,
servants and/or employees had a duty to provide ade-
quate supervision of individuals on the Rockstar prem-
ises; and that the plaintiff’s injuries were the result of
the defendant’s negligent supervision in failing, among
other things, to monitor Booker and remove her from
the premises for showing signs of aggressiveness.
Accordingly, the complaint alleges a duty to monitor
its employees and a breach of that duty that caused
actual injury.12 When we construe the complaints
broadly, realistically, and in the manner most favorable
to sustaining their legal sufficiency, considering the
facts necessarily implied from the allegations; see
Kumah v. Brown, supra, 127 Conn. App. 259; we con-
clude that the allegations are sufficient to set forth a
cause of action for negligent supervision.

For the foregoing reasons, as detailed in part IV A
and B of this opinion, we conclude that the trial court
improperly struck the negligent supervision counts of
the operative complaints.

The judgments are reversed only as to counts two,
four, five, six, and eight of the operative complaint in
Docket No. CV-XX-XXXXXXX-S and as to counts two and
12
We note that there was no argument asserted in the motions to strike and
no argument on appeal regarding the legal existence of a duty of employers
to monitor their employees for aggressiveness. ‘‘In ruling on a motion to
strike the trial court is limited to considering the grounds specified in the
motion.’’ Meredith v. Police Commission, 182 Conn. 138, 140, 438 A.2d
27 (1980).
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four of the operative complaint in Docket No. CV-22-
6064603-S; the judgments are affirmed in all other
respects.
In this opinion the other judges concurred.