Ulbrich v. Groth (2013)

Personalty holding

A bank auctioned business equipment alongside a court-supervised realty foreclosure. The buyer later discovered third-party ownership claims. The court upheld title-warranty/CUTPA recovery: generic as-is/where-is and right/title/interest language did not adequately disclaim title under §§ 42a-2-312 and 9-610. Combining the sales did not impose realty caveat emptor on the Article 9 personalty. Full majority opinion, part III and notes 34–38.

The court reversed the negligence/negligent-misrepresentation rulings under the economic-loss doctrine, while preserving the distinct CUTPA recovery. It also remanded the nontaxable-cost issue. Full opinion, parts I–II, VIII and disposition.

Limits and later treatment

The holding does not enlarge the debtor’s title or import Article 9 into excluded statutory service liens. connex-credit-union-v-madgic-2026 expressly distinguishes Ulbrich when rejecting automatic use of Article 2’s limitation period for statutory Article 9 notice-damages claims. Full later opinion, part I B.

Primary bodies retrieved October 17, 2026; comprehensive later treatment is not certified. See connecticut, equipment-and-machinery.

Bounded final review (2026-10-18)

Not re-verified: the Judicial Branch opinion and concurrence refused automated access (HTTP 403), no Caselaw Access Project record exists at the expected path (404), and cases.justia.com is not used; the Connecticut module therefore no longer links or relies on this page. Comprehensive later treatment remains needs_verification; no citator certification is made.

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