Co-authored by: Jon Biller & Brianna Robert
In a victory for Liberty Automotive, Inc. d/b/a Liberty Mazda of Hartford, our Associate Attorney Niki Abossedgh successfully argued for treble damages under Connecticut General Statutes § 52-564, following a hearing in damages before Judge Robert B. Shapiro in the Connecticut Superior Court, JD of Hartford in Liberty Automotive, Inc. d/b/a Liberty Mazda of Hartford v. Ernest Davis.[1]
The case stemmed from a 2023 incident in which the Defendant took a 2023 Mazda 3 for a test drive under a signed temporary loan agreement but failed to return it and instead, reported it stolen. About 51 days later, the vehicle was ultimately recovered—damaged and found to be in the possession of the Defendant during that 51 day duration.
As a result of the Defendant’s misconduct and false reporting, Liberty Mazda incurred over ten thousand dollars in repair costs. At a hearing in damages held on February 26, 2025, Attorney Abossedgh presented testimonial and documentary evidence demonstrating not only breach of contract but also a willful and wrongful exercise of control over the property—a textbook case of statutory conversion.
Connecticut General Statutes § 52-564 provides that “[a]ny person who steals any property of another, or knowingly receives and conceals stolen property, shall pay the owner treble his damages.”[2] In other words, if the conduct qualifies as statutory theft, the plaintiff is entitled to triple the proven damages.
The Superior Court agreed with Attorney Abossedgh’s position and found that the Defendant’s conduct met the statutory criteria for theft.
Judge Shapiro entered judgment in favor of Liberty Mazda in the full treble damages.
This ruling underscores the remedy that Connecticut’s statutory theft law provides to victims of conversion. As Attorney Abossedgh argued, when a defendant’s conduct rises to the level of intentional misappropriation, courts have discretion to impose treble damages—not merely to compensate the victim, but to deter willful misconduct.
We are proud to congratulate Associate Niki Abossedgh on her first courtroom win.
[1] See Liberty Automotive, Inc. d/b/a Liberty Mazda of Hartford v. Davis, No. HHD-CV24-6181731-S (Conn. Super. Ct. Mar. 5, 2025).
[2] See Conn. Gen. Stat. § 52-564