The following article was first published on Shipman & Goodwin attorney Dan Schwartz’ Connecticut Employment Law Blog. It is reposted here with permission.
A new decision from the state Appellate Court, Paniccia v. Success Village Apartments, Inc., delivers some clarity for employers facing wage claims under Connecticut General Statutes § 31-72.
The bottom line?
When employees win wage cases, the “costs” they can recover are limited to statutory taxable costs—not every litigation expense they incurred.
David Paniccia sued his former employer for unpaid wages and ultimately prevailed, recovering $172,969.90 in damages.
Under § 31-72, successful plaintiffs in wage cases can recover “twice the full amount of such wages, with costs and such reasonable attorney’s fees as may be allowed by the court.”
Paniccia got his double damages and $225,000 in attorney’s fees. But then he asked for an additional $10,821.78 in costs—including filing fees, deposition transcripts, process server fees, parking, photocopying, focus group expenses, and various other litigation expenses.
The trial court said no, limiting Paniccia’s cost recovery to statutory taxable costs under General Statutes §§ 52-257 and 52-260.
Rather than take the overall victory, Paniccia appealed, arguing that “costs” under § 31-72 should include all reasonable and necessary litigation expenses. (No doubt the appeal cost more than the costs, but that’s an issue for another day.)
The Appellate Court affirmed the trial...
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