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******************************************************TOWN OF LEDYARD v. WMS GAMING, INC. (AC 39746)
DiPentima, C. J., and Beach, Alvord, Sheldon and Prescott, Js.*
Considered December 14, 2016—officially released March 21, 2017 (Appeal from Superior Court, judicial district of New

London, Vacchelli, J.) Lloyd L. Langhammer, in support of the motion.
Aaron S. Bayer and David R. Roth, in opposition to the motion.Opinion DiPENTIMA, C. J. The motion before the court challenges ourjurisdiction overthe appeal ofthe defendant, WMS Gaming, Inc., from the decision of the trial court renderingsummaryjudgmentastoliabilityonlyinfavor of the plaintiff, the town of Ledyard, with respect to certain attorney’s fees incurred by the plaintiff. The plaintiff moves to dismiss the defendant’s appeal for lack of subject matter jurisdiction, claiming that the trial court’s decisionisnotanappealable finaljudgment because the trial court has not determined the amount ofthe attorney’s fees. We conclude that the trial court’s decision rendering summary judgment as to liability onlyinfavoroftheplaintiffwithregardtothe attorney’s fees at issue is not an appealable final judgment. Accordingly, we grant the plaintiff’s motion to dismiss the defendant’s appeal.
The record before the court reveals the following facts and procedural history. In 2008, the plaintiffcommencedtheunderlyingactiontocollectunpaidpersonal propertytaxesthatithadimposedonslotmachinesthat the defendant owned and leased to the Mashantucket Pequot Tribal Nation (Tribal Nation) for use in its gaming facilities. As relief, the plaintiff sought $18,251.23 in unpaid personal property taxes, plus costs, interest, andpenalties. Inaddition, theplaintiffsoughtattorney’s fees pursuant to General Statutes § 12-161a. Shortly after the plaintiffhad commenced the underlying state action, the Tribal Nation filed an action in the United States District Court for the District of Connecticut challenging the authority of the state of Connecticut and the plaintiff 1 to impose the taxes at issue in the present state action.2 Although it was not aparty to the federal action commenced by the Tribal Nation, the defendant filed a motion to stay the present state actionpendingthe outcome ofthe federalaction, which the trial court, Martin, J., granted.
On March 27, 2012, the District Court ruled on cross motionsforsummaryjudgmentfiledinthe consolidated federal action. The District Court, determining that the authority of the state and the plaintiff to impose the taxes was preempted by federal law, granted the Tribal Nation’s motion forsummaryjudgment and denied separate motions for summaryjudgment filed by the plaintiff and the state, respectively. See Mashantucket Pequot Tribe v. Ledyard, United States District Court, Docket No. 3:06CV1212 (WWE), 2012 WL 1069342, *12 (D. Conn. March 27, 2012), rev’d, 722 F.3d 457 (2d Cir. 2013). On July 15, 2013, the United States Court of Appeals for the Second Circuit reversed the District Court’s judgment, concluding that the authority of the state and the plaintiff to impose the taxes was not preempted by federal law. See Mashantucket Pequot Tribe v. Ledyard, 722 F.3d 457, 477 (2d Cir. 2013).After the proceedings had resumed in the present state action, the parties executed a stipulation. Under the stipulation, the parties agreed that the defendant hadtenderedpaymenttotheplaintiffforall outstanding taxes, accrued interest, and accrued penalties at issue. They further agreed that the plaintiff was entitled to reasonable attorney’s fees and costs incurred in the underlying state action, the amount ofwhich would be determined bythe trial court and the payment ofwhich would be accepted by the plaintiff as satisfaction of all of the taxes, interest, penalties, attorney’s fees, and costs recoverable by the plaintiff with respect to the underlying state action. They disputed, however, whether the trial court could also find the defendant liable for attorney’s fees incurred by the plaintiff in defense ofthe federal action commenced by the Tribal Nation to which the defendant was not aparty (federal action attorney’s fees). The parties agreed to submit to the trial court the issue of whether the defendant was liable for the federal action attorney’s fees.
After executingthe stipulation, the parties filed cross motions for summaryjudgment as to liability only with respecttothefederalactionattorney’sfees. On October 6, 2016, thetrialcourt, Vacchelli, J., issueditsmemorandum ofdecision granting the plaintiff’s motion for summary judgment, denying the defendant’s motion for summaryjudgment, and rendering summaryjudgment
as to liability only in favor of the plaintiff with respect to the federal action attorney’s fees. The trial court concluded that the defendant was liable for the federal action attorney’s fees pursuant to § 12-161a.3 The trial court furtherstatedthatthe plaintiffcould file amotion for attorney’s fees within thirty days and that a hearing wouldbe scheduledthereafterto determinethe amount of the attorney’s fees to which the plaintiff is entitled. Shortly thereafter, on October 11, 2016, the plaintiff filed a motion for attorney’s fees.
On October 25, 2016, prior to the trial court scheduling a hearing on the plaintiff’s motion for attorney’s fees, the defendant appealed the trial court’s decision with respect to the federal action attorney’s fees. The plaintiff’s motion to dismiss the defendant’s appeal followed.
The plaintiffmoves to dismiss the defendant’s appeal for lack of subject matter jurisdiction, asserting that the trial court’s decision rendering summaryjudgment
as to liability only in favor of the plaintiff with respect to the federal action attorney’s fees is not an appealable final judgment because the trial court has not determined the amount of the attorney’s fees to which the plaintiffis entitled. Inresponse, the defendant contends that the trial court’s decision is immediately appealable under the rationale ofHylton v. Gunter, 313 Conn. 472, 97 A.3d 970 (2014). We agree with the plaintiff.‘‘As a preliminary matter, we set forth the standard of review. The lack of a final judgment implicates the subject matterjurisdiction ofan appellate court to hear
an appeal. A determination regarding

. . . subject matter jurisdiction is a question of law

. . . [and, therefore] our review is plenary.

. . . The right of appeal is accorded only ifthe conditions fixed by statute and the rules ofcourt fortaking and prosecuting the appeal are met.

. . . It is

. . . axiomatic that, except insofar as thelegislaturehasspecificallyprovidedforaninterlocutory appeal or other form of interlocutory appellate review

. . . appellate jurisdiction is limited to final judgments ofthe trial court.’’ (Citation omitted; internal quotation marks omitted.) Id., 478.
We begin our analysis with a review ofParanteau v. DeVita, 208 Conn. 515, 544 A.2d 634 (1988). In Paranteau, the plaintifftenants sued the defendant landlord, alleging, inter alia, aviolation ofthe Connecticut Unfair Trade Practices Act, General Statutes §§ 42-110a et seq. Id., 517. Thetrial courtrenderedjudgmentonthe merits in favor of the plaintiffs on all counts and implicitly awarded them attorney’s fees pursuant to General Statutes § 42-110g (d), but delayed determining the amount ofthe attorney’s fees. Id. Following a hearing held over twenty days after thejudgment had been rendered, the trial court determined the sum ofthe attorney’s fees to be $2580. Id. The defendantinParanteaufiledanappeal eight days after the hearing, challenging both thejudgment on the merits as well as the supplemental postjudgment attorney’s fees order. Id., 518. The plaintiffs timelyfiledamotiontodismisstheappealontheground that it was untimely. Id. This court granted the motion to dismiss and dismissed the appeal in toto. Id.
After granting the defendant’s certification to appeal inParanteau, our Supreme Court reversed this court’s judgment in part. Id. Our Supreme Court first determined that this court properly had dismissed, as untimely, theportion ofthe appeal challengingthejudgment on the merits, concluding that ‘‘ajudgment on the merits is final for purposes of appeal even though the recoverabilityoramount ofattorney’sfeesforthe litigation remains to be determined.’’ Id., 523. It then determined that this court had improperly dismissed, as untimely, the portion ofthe appeal challenging the trial court’s supplemental postjudgment attorney’s fees order, concludingthat ‘‘suchan ordermayraise acollateralandindependentclaimthatisseparatelyappealable
as a final judgment.’’ Id. In a footnote, it further explained: ‘‘A supplemental postjudgment award of attorney’s fees becomes final and appealable

. . . not when there is a finding of liability for such fees, but when the amount of fees are conclusively determined. A finding as to liability only, prior to a determination
on the issue of damages, is not a final judgment from which an appeal lies.

. . . Furthermore, a timelyappeal from a supplemental postjudgment award of attorney’s fees may challenge not only the amount awarded, but the underlying recoverability ofsuch fees
as well.’’ (Citation omitted.) Id., 524 n.11.4
This court has relied on Paranteau to dismiss appeals, inwhole orinpart, challengingawards ofattorney’s fees where the appeals were filed prior to the conclusive determinations of the amount of the attorney’s fees. See Bailey v. Lanou, 138 Conn. App. 661, 675–77, 54 A.3d 198 (2012) (dismissing, sua sponte, portion ofappeal challenging award ofstatutory attorney’s fees where trial court had not determined amount of attorney’s fees prior to filing of appeal); McKeon v. Lennon, 131 Conn. App. 585, 610–11, 27 A.3d 436 (dismissing portion of appeal challenging award of attorney’s fees where trial court had not determined amount ofattorney’s fees priorto filing ofappeal), cert. denied, 303 Conn. 901, 31 A.3d 1178 (2011);5Sullivanv. Brown, 116 Conn. App. 660, 661 n.1, 662–63, 975 A.2d 1289 (dismissing, sua sponte, appeal challenging award of statutory attorney’s fees and costs where trial court had not determined amount ofattorney’s fees and costs prior to filing of appeal), cert. denied, 294 Conn. 914, 983 A.2d 852 (2009); see also Burns v. General Motors Corp., 80 Conn. App. 146, 150–51 n.6, 833 A.2d 934 (noting, in dictum, that award of statutory attorney’s feeswasnotappealablefinaljudgmentwheretrialcourt had not determined amount of attorney’s fees prior to filing of appeal), cert. denied, 267 Conn. 909, 840 A.2d 1170 (2003).
The defendant relies onHylton v. Gunter, supra, 313 Conn. 472, to support its assertion that the trial court’s decision rendering summary judgment as to liability only in favor ofthe plaintiffwith respect to the federal actionattorney’sfeesisimmediatelyappealable. InHylton, thepartieswere equalmembers ofalimitedliability company. Id., 475. The plaintiff sued the defendant, raising claims, inter alia, of fraud and negligence on the basis of allegations that the defendant had been misappropriating the limited liability company’s funds for his personal use. Id. The trial court rendered judgment on the merits in favor ofthe plaintiffon all counts and awarded him compensatory damages. Id. The trial court also awarded the plaintiff common-law punitive damages in the form of attorney’s fees and instructed the plaintiffto file an affidavit of attorney’s fees within thirty days. Id. The defendant appealedpriorto the trial court’s determination of the amount of the attorney’s fees, and he did not amend his appeal once the trial court had rendered ajudgment establishing the amount of the attorney’s fees. Id., 475–76.
This court placed the appeal in Hylton on its own motion calendar for a determination of whether the appeal shouldbe dismissed forlack ofafinaljudgment. Id., 476. After the motion hearing, this court markedthe matter over. Id. The parties subsequently briefed the final judgment issue and argued the issue as part ofthe appeal. Id. This court subsequently dismissedthe appeal for lack ofan appealable finaljudgment, relying upon its prior decision in Lord v. Mansfield, 50 Conn. App. 21, 717 A.2d 267, cert. denied, 247 Conn. 943, 723 A.2d 321 (1998), overruled by Hylton v. Gunter, supra, 313 Conn. 488–89. SeeHyltonv. Gunter, 142 Conn. App. 548, 554, 66 A.3d 517 (2013), rev’d, 313 Conn. 472, 97 A.3d 970 (2014). InLord, this courtheldthat ajudgment is not final for purposes ofappeal where the trial court awards common-law punitive damages without determining the amount of the common-law punitive damages. Lord v. Mansfield, supra, 24, 28. In reaching that conclusion, this court determined that commonlaw punitive damages, unlike attorney’s fees, serve the purpose of compensating the injured party fully and
are not wholly separate from a judgment rendered on the merits. Id., 26–28.
After granting the defendant’s petition for certification to appeal, our Supreme Court reversed this court’s judgment. Hylton v. Gunter, supra, 313 Conn. 477–78. After analyzing Paranteau and subsequent cases,6 it determined that the judgment rendered on the merits
was an appealable finaljudgment, even though the trial court had not determined the amount ofthe attorney’s fees awarded as common-law punitive damages prior to the filing ofthe appeal. Id., 479–84. It concluded that the bright line rule articulated in Paranteau, namely, that ‘‘ajudgment on the merits is final for purposes of appeal even though the recoverability or amount of attorney’s fees for the litigation remains to be determined’’; (internal quotation marks omitted) id., 480; applied equally in the context of common-law punitive damages. Id., 484. In reaching its conclusion, our Supreme Court declined to distinguish attorney’s fees awardedpursuant to the applicable statutes from attorney’s fees awarded as common-law punitive damages, determining that common-law punitive damages are akin to statutory attorney’s fees ‘‘in practicality and purpose, insofar as both provide the same relief and
serve the same function

. . . namely, fully compensating injured parties.’’ (Citation omitted; footnote omitted; internal quotation marks omitted.) Id., 484–86. Our Supreme Court also emphasized that its approach ‘‘suggeststhatwhatis ofimportancehereisnotpreservation of conceptual consistency in the status of a particular fee authorization as ‘merits’ or ‘nonmerits,’ but rather preservation of operational consistency and predictability in the overall application of [the final judgment rule].’’ Id., 487. Hylton expressly overruled this court’s judgment in Lord

. Id., 488–89.7
The defendant asserts that, under the rationale of Hylton, the trial court’s decision rendering summary judgment as to liability only in the plaintiff’s favor with respect to the federal action attorney’s fees is immedi-ately appealable. According to the defendant, Hylton provides that a liability determination with respect to attorney’s fees awarded as damages may be appealed before the amount ofthe attorney’s fees is determined. The defendant claims that the federal action attorney’s fees are similarin nature to the attorney’s fees awarded
as common-law punitive damages inHylton and, therefore, thetrialcourt’sliabilitydeterminationwithrespect to the federal action attorney’s fees is appealable immediately. We are not persuaded.
In Hylton, our Supreme Court held that a judgment rendered on the merits, which included an award of common-law punitive damages limited to attorney’s fees, was an appealable finaljudgment notwithstanding the lack of a determination of the amount of the attorney’s fees at the time that the appeal was filed. In the presentcase, thetrialcourthasnotrenderedajudgment disposing of the merits of the present action.
The defendant is appealing only from the trial court’s decision rendering summary judgment as to liability only in favor ofthe plaintiffwith respect to the federal action attorney’s fees, which were awarded pursuant to § 12-161a. Hylton does not stand for the proposition thatthe trial court’s liability determinationwith respect to the federal action attorney’s fees is immediately appealable absent a calculation of the attorney’s fees.8
Pursuant to the rationale of Paranteau, a timely appeal taken from a decision conclusively determining the amount of an attorney’s fees award may challenge both the amount and recoverability of the attorney’s fees awarded. Applying the rationale of Paranteau to the circumstances of the present action, we conclude that the trial court’s decision rendering summaryjudgment as to liability only in the plaintiff’s favor with respect to the federal action attorney’s fees is not an appealable final judgment absent a determination of the amount of the attorney’s fees.9 See also Burns v. GeneralMotorCorp., supra, 80 Conn. App. 151 n.6 (‘‘The situation

. . . is similar to where ajudgment has been rendered only upon the issue of liability without an awardofdamages. Suchajudgment, beinginterlocutory in character, is not a final judgment from which an appeal lies.

. . . Thus, the award of reasonable attorney’s fees without a determination of the amount of the attorney’s fees is not appealable for lack of a final judgment.’’ [Citation omitted; internal quotation marks omitted].).
The plaintiff’s motion to dismiss the defendant’s appeal is granted and the appeal is dismissed.
In this opinion the other judges concurred.

* The listing of judges reflects their seniority status on this court as of the date on which this matter was considered.

1 The plaintiff’s tax assessor and the plaintiff’s tax collector were also parties to the federal action.

2 In 2006, the Tribal Nation filed a substantively similar federal action challenging, as unauthorized, taxes that the plaintiff was imposing on slotmachines that a different vendor owned and leased to the Tribal Nation. Thetwofederalactions commencedbythe TribalNationwere consolidated.

3 General Statutes § 12-161a provides: ‘‘In the institution of proceedings by any municipality to enforce collection of any delinquent tax on personal property from the owner of such property, through (1) levy and sale with respect to any goods or chattels owned by such person, (2) enforcement of a lien, established and perfected in accordance with sections 12-195a to 12-195g, inclusive, upon any such goods or chattels or (3) any otherproceeding in law in the name of the municipality for purposes of enforcing such collection, such person shall be required to pay any court costs, reasonable appraiser’s fees or reasonable attorney’s fees incurred by such municipality

as a result of and directly related to such levy and sale, enforcement oflien

or other collection proceedings.’’

4 With respect to the effect ofits decision, our Supreme Court stated: ‘‘We

are aware that the rules we have today adopted may, in some cases, lead to ‘piecemeal’ appeals ofjudgments on the merits and awards of attorney’s fees. The problem of fragmented appeals, however, may be averted if trial judges delay renderingjudgment on the merits until the fee issue is resolved and dispose of both the merits and attorney’s fees in a single judgment.

. . . If for some reason the question of attorney’s fees must be decided after the entry of judgment on the merits, we suggest that the trial court insist upon the prompt filing and disposition of fee requests so that any pending appeal on the merits ofthe action may be amended to include any prospective appeal from a supplemental postjudgment award of attorney’s fees.’’ (Citation omitted; emphasis omitted.) Paranteau v. DeVita, supra, 208 Conn. 524.

5 In McKeon, the plaintiff filed an amended appeal after the trial court had held a hearing and had determined the amount of the attorney’s fees atissue inthat case. McKeonv. Lennon, supra, 131 Conn. App. 610. Although this court dismissed the plaintiff’s original appeal for lack of an appealable finaljudgment, it concluded that it had subject matterjurisdiction over the plaintiff’s amended appeal. Id., 611–12.

6 See Benvenuto v. Mahajan, 245 Conn. 495, 504, 715 A.2d 743 (1998) (concluding that judgment of strict foreclosure was appealable final judgment despite lack of determination of attorney’s fees); Balf Co. v. Spera Construction Co., 222 Conn. 211, 214–15, 608 A.2d 682 (1992) (concluding that no appealable finaljudgment had been rendered where trial court had reserved ruling on postjudgment motion for prejudgment interest).

7 On remand from our Supreme Court, this court reversed the trial court’s judgment on the merits and ordered the trial court, on remand, to render judgment in favor ofthe defendant on one count ofthe plaintiff’s complaint and to conduct a new trial on the remaining counts. See Hylton v. Gunter, 157 Conn. App. 358, 366, 116 A.3d 371 (2015).

8 The defendant also asserts that we should entertain this appeal for the sake of efficiency, claiming that, if held, the proceedings to determine the amount of the attorney’s fees owed to the plaintiff will be extensive and that suchproceedings will be avoided ifwe reverse the trial court’s decision. In addition, the defendant suggests that, by entertaining this appeal, we may provide the trial court and the parties with guidance with regard to the meaning and application of § 12-161a. These considerations, however, cannot be reviewed at this time as a result of our lack of subject matter jurisdiction over this appeal.

9 Our holding is limited to the circumstances ofthe present action before

us. We do not address the appealability of this matter should an appeal be filed following a decision of the trial court determining the amount of the federal action attorney’s fees.