Connecticut Trial Firm’s No Wait Guarantee

We hate waiting. This is Connecticut Trial Firm, LLC’s “No Wait” Guarantee.

If we don’t see you within 5 minutes of a scheduled meeting time at our office we’ll give you a $25 Amazon Gift card. Your time matters to us. Your personal injury case matters to us. You matter to us.

Call us to discuss your Connecticut personal injury case. Call Connecticut Personal Injury Attorney Ryan McKeen at 860 471 8333. Call now. Don’t wait.

Connecticut Personal Injury Attorney Ryan McKeen getting an award from the CT Personal Injury Hall of Fame.
Connecticut Personal Injury Attorney Ryan McKeen getting an award from the CT Personal Injury Hall of Fame. Connecticut Trial Firm’s No Wait Policy.

Road Injury In Connecticut

CT Road Injury
Contact CT Road Injury Attorney Ryan McKeen

Have you been injured by a pothole while riding a bike? Have you suffered a road injury in Connecticut?  These injuries can be very serious. They often result in broken bones.

What are your legal rights? Is the town responsible for the damage to your bike? For your medical bills? For your pain?

A Defective Road Claim

Connecticut law provided that a person who was injured by means of a defective road may recover damages from the party bound to keep it in repair.

In making a claim, a person must prove all of the following elements by a fair preponderance of the evidence:

1) that she gave the required statutory notice of injury;

2) that the sidewalk where the injury occurred was one that the (city / town /
borough) and not some other person or entity had a duty to maintain or repair;

3) that there was a defect in the road;

4) that the city had notice of the defect;

5) that the city failed to exercise reasonable care to remedy said defect; and

6) that the defect was the sole proximate cause of the plaintiff’s injuries; that is, no
other cause was a substantial factor in causing her injuries.

All of these elements must be proven.

Why You Need To Contact A CT Personal Injury Attorney Immediately

The statute states that an action can only be brought to recover damages caused by a defective sidewalk if the plaintiff provides written notice of the injury, with a general description of the injury, the cause, the time, and the place of its occurrence. This notice shall be given within ninety days thereafter to a selectman or clerk of the town, city or borough bound to keep the sidewalk in repair.

The notice mandated by the statute includes five elements: 1) written notice of the injury, 2) a general description of the injury, 3) the cause, 4) the time, and 5) the place.

Giving notice doesn’t mean you have to file a case. But doing so is necessary to preserving your claim for a road injury.

If proper notice isn’t given, you have no case.

The same rules apply to being injured on a sidewalk. You can learn more about sidewalk injuries here. 

Road Injury Legal Malpractice

We have brought claims against lawyers who fail to give proper notice in a timely fashion. The notice provision for road defects is unforgiving. If your lawyer didn’t give notice or gave improper notice you may have a legal malpractice claim.

If you would like your case evaluated at no cost please contact Attorney Ryan McKeen at 860 471 8333.

Connecticut Dog Bite Law

What you need to know about Connecticut Dog Bite law.

Dog bites can cause serious permanent injury or death. Even a “small” bite can lead to serious infection that results in surgery or hospitalization. Many of my dog bite cases begin with an owner saying “(insert dog’s name) would never bite anyone.

I have been bitten by a dog several times. Once I was ripped off my bike by a dog, I understand. It happens so fast. Fortunately, I was okay. Just a pair of ripped jeans. Other folks aren’t so lucky.

Anyone who owns or keeps a dog is held strictly liable under our law for any damage caused by the dog. Strict liability does not depend on intent or harm. A person is liable if something happens – in this case a dog bite – whether or not they did anything wrong.

Connecticut Dog Bite Law
Contact Connecticut Dog Bite Attorney Ryan McKeen 860 471 8333

Connecticut Dog Bite Law

“If any dog does any damage to either the body or property of any person, the owner or keeper,  shall be liable for such damage, except when such damage has been occasioned to the body or property of a person who, at the time such damage was sustained, was committing a trespass or other tort, or was teasing, tormenting or abusing such dog.” Connecticut General Statutes § 22-357

Who Is A Keeper Of The Dog

A “keeper” of a dog means someone other than the owner who harbors or has possession of any dog. You can read more about Who is a dog’s keeper here.

Exceptions To Strict Liability Dog Bites

There are two exceptions “strict liability.” The first is that the person bitten by the dog was committing a “trespass or other tort.” A “tort” is a wrongful act.

“Committing a trespass or other tort” means more than merely entering on the property or in the area where the dog was, but rather entering to commit an injury or a wrongful act. This means such wrongful acts committed against the person or property of the owner or keeper or his family. For example if a dog bites a home invader there is no liability.

The second is “teasing, tormenting, or abusing” the dog. Teasing, tormenting or abusing a dog means engaging in actions that would naturally annoy or irritate a dog and provoke it to retaliation. You can read more about the tormenting defense here. 


The plaintiff must prove are 1) that the defendants were the owners or keepers of a dog, 2) that the dog did, in the language of the statute, “any damage to . . . the body or property” of the plaintiff, and 3) that neither of the exceptions applies.

Know your right about Connecticut dog bite law. Empower yourself with more information about Connecticut dog bite law. Get a free consultation with me.

How much is my case worth? Contact experienced CT dog bite attorney Ryan McKeen at 860 471 8333 for a free case evaluation. You can read about one of Ryan’s recent dog bite verdicts here.

Be Kind To Yourself

One of the great struggles I’m having in reclaiming my life as a runner is being kind to myself.

There’s a voice in my head that says terrible things. Things that I would never say to anyone else. Things like “you’re so out of shape” or “you are so slow” or “you are so fat”. And even worse things like “you’ll never get back into shape”. Those days of going out and running 15 miles for fun are over. And they’re never coming back.

It pains me to write those words. I am not giving myself space for empathy. And I don’t know why.

I wonder if my injured clients go through the same things. Are they hard on themselves because the house isn’t as clean as it used to be? Or suddenly their mind doesn’t work the way it used to be? Or suddenly because they are mobility impaired they have gained weight? Or maybe they can’t attend their kids school event? Are they being kind to themselves? It is something I have to start asking in my interviews with clients.

One of the things that I’m doing is imagining in shape me training out of shape me. In shape me would be a cheerleader. In shape me would know that keeping at it will quickly unlock gains. In shape me would say won step at a time. And pat out of shape me on the back.

I wonder why this is so hard. I don’t have an answer. The only thing I know is it helps to write this. It helps sharing this.

I’m going for a run. I’m going to cheer for myself. My goal isn’t time, distance, or duration, My goal is self empathy.

I hope whatever you are struggling with you create a space to be kind to yourself.

You can read post 1 in the series here.

You can read post 2 in the series here.


Ask About Legal Malpractice Insurance

Hiring a lawyer? Ask this question about legal malpractice insurance. Also checkout my first Facebook live video below.

This post deals with legal malpractice Insurance. I have done 100s if not 1000s of potential client interviews. I have never been asked about my insurance.

Connecticut lawyers are not required to insurance. Nor are they required to disclose that they don’t carry legal malpractice insurance.

Lawyers can commit legal malpractice in a variety of ways. The most common way is failing to file suit within the statute of limitations period or failing to give proper notice.  Lawyers can also commit malpractice by wrongfully settling your case. Make no mistake about it, legal malpractice insurance protects clients.

Every lawyer can make a mistake. Experienced lawyers. New lawyers. At firms large and small. To err is to human. Law is harsh. Law has a lot of deadlines.


My partner, Andrew Garza writes in response to the video: I can’t agree more. Time and time again I’ve told fellow attorneys that legal malpractice insurance is not just for them (though it is certainly important to protect yourself too). It’s a sign that the lawyer truly cares about their clients. No lawyer wants to make a mistake. But, every lawyer should want to make sure their client’s recovery is not lost if a mistake does happen.

Ask Us About Legal Malpractice Insurance

Your case is important. Don’t wait until it is too late to find out your lawyer doesn’t carry insurance. Empower yourself. Ask the question directly to the lawyer you are interviewing. The answer should be straightforward.

Connecticut Trial Firm LLC carries legal malpractice insurance. We welcome tough questions from potential clients. If you have a question about a Connecticut legal malpractice case contact Ryan at 860 471 8333.

Does Your Lawyer Have Legal Malpractice Insurance?
Does Your Lawyer Have Legal Malpractice Insurance?

Ruby Receptionists Review

On this episode of “Ask Ryan” I review Ruby Receptionists.  Ruby Receptionists answers phones. That is what they do. This is my Ruby Receptionists review.

I answered my phones for the first two years of practice. It wore on me. It made it hard to get work done. All I was doing was answering my phone. Lawyers are in a client service business. Answering the phones is a key component of satisfying clients.

And equally as bad, I was missing out on clients. One day I had a potential client call me with two new cases. The cases were good cases. The client had found me online. I called him back 15 minutes later and he already had hired another lawyer. There’s the quick and the dead.

By not having not having a receptionist I was failing. I was failing myself. I was failing my clients. And I was failing my business.

Ruby Receptionists Review
Ruby Receptionists Review

Ruby Receptionists answers phones. They answer my phones. And they have answered them well for nearly the last 2 years.

I haven’t had to train anyone. No additional space is needed in my office. There’s no need to add anyone to the payroll. My assistant’s time is maximized because she can focus on pleadings, discovery, and other important matters. She does not have to answer the phone.

Ruby takes the time to set up and understand my call settings. Any changes to my settings are quickly implemented. Changing my settings is as easy as opening an app on my phone or calling Ruby.

Watch below for my Ruby Receptionist Review where I discuss the pros and cons of using Ruby. I am not paid for this review. I receive nothing in exchange for post this. My thoughts are my own.

If you’d like to ask me a question for an upcoming episode of “Ask Ryan” please shoot me an email at

Car Accident Insurance Company Has Offered Me Money

The Insurance Company Has Offered Me Money From My Car Accident. Do I Take It?

I was in a car accident. The other person’s insurance company claims they have “accepted responsibility”. And they want me to sign releases. They want me to sign a release giving them access to my medical records. And they want me to sign a release saying I won’t sue them. I’m not a lawsuit happy person. I just want what is fair. And the insurance company tells me that if I hire a lawyer I will get less money because the lawyer will take a fee.

I’d like to talk with a lawyer. I have no idea if what they are offering me is fair. And I certainly don’t want to give a third of what the insurance company is offering to the lawyer. Then I would have less money.

CT Car Accident Attorney
Contact CT Car Accident Attorney Ryan McKeen. 860 471 8333

What Do I Do About My Car Accident Case

The insurance company is deploying advanced psychological tactics to get you to accept their offer. One of the tactics is loss aversion: it’s better to not lose $5 than to find $5. Read more about insurance company tactics here. 

The reason the insurance company is deploying these tactics is in hopes of saving a buck. If the car accident claim is objectively worth 20k and they can get a release for 2k – they look at it as making 18k on your car accident claim.

The Car Accident Solution

Have your case evaluated by a personal injury lawyer.

Tell your personal injury lawyer about the offer. An honest lawyer will give you a straight evaluation if possible. And usually it is easy. Usually the reason the insurance company has offered money at all is because they know the claim is worth many times what they are offering.

I can’t speak for other lawyers, but if you see me I will not accept a case where I can’t help my client. If the insurance company has offered a potential client 3k and I take a third of that and the client now receives 1k – I have made the client worse off. That’s not fair.

Insist on a free case evaluation. Insist that your lawyer not take the case if he can’t help you. Get it put in writing in your fee agreement.

Contact me if you have been in a Connecticut car accident. There is never a fee for my evaluation. And I put my money where my mouth is. 860 471 8333

You may also like my post “Do I Have A Personal Injury Case? 


Wrongful Death Damages

Wrongful death damages in Connecticut.
Wrongful death damages in Connecticut.

Few things are as hard in law as calculating wrongful death damages.

Life is the most rare of things in the universe. There is a lot of rock out there. A lot of dust too. But in the scope of all we know, human a life is truly unique and special.

Connecticut law compensates plaintiffs in wrongful death cases for both economic and non-economic damages. You can read about the difference here.  This post deals with non-economic damages in wrongful death cases.

Non-economic damages in the wrongful death action consist of (1) any pain and suffering experienced before death, (2) the loss of the life itself, and (3) the destruction of the ability to continue life’s activities.

What The Jury Can Consider For Wrongful Death Damages

In evaluating the damages for the loss of the life and the destruction of the ability to continue life’s activities, the fact finder must consider the details of the decedent’s life. The lawyer for decedent’s estate is must present an overall picture of the decedent’s activities to enable the jury to make an informed evaluation of the total destruction of the decedent’s ability to carry on life’s activities.

This includes the loss of the ability to marry and have a family, and the loss of the ability to pursue a career and become involved in community activities. Hobbies, recreations, and missing important future events may be considered.  For example, if the decedent was a lifelong Cubs fan and they win the World Series just after his death – a jury may consider that as a compensable event.

What The Jury Can’t Consider For Wrongful Death Damages

The jury can’t consider the issues from the standpoint of the estate’s beneficiaries. This is a difficult prism in which these cases operate. The tears of a son missing a father aren’t to be considered. What a jury considers is the father’s loss of spending time with his son.  The financial needs of the beneficiaries can’t be considered. It doesn’t matter if the kids are wealthy or poor.  And most interestingly, the remarriage of the decedent’s spouse does not affect the damages for the wrongful death.

Wrongful Death Summary

The wrongful death cases that I have worked on have been some of the hardest cases of my career. Figuring out how to capture the essence of the person who has been killed requires a lot of time. And more than time it requires a lot of empathy. It means going to dark places. The void the loss has created in the universe. It means going to the person’s home. Sitting in their chair. Going to where they worked. Breaking bread with the family. Spending time in the house. Looking at the loved one’s books. Trying desperately to capture who the person was. It is the only way any lawyer can convey the loss of father, or daughter, or son, or mother to a jury, judge or mediator.

Click here for a wrongful death jury verdict form. You can see how a Hartford jury valued a life in 2014. A task I don’t envy. But work that must be done.

Loss of Consortium And Car Insurance

Can I recover for my loss of consortium claim?
Can I recover for my loss of consortium claim?

Can a spouse recover as an independent claim under an auto policy? This post discusses the relationship between loss of consortium and car insurance.

This question is a very important one. I see this issue arising more and more in my cases.  The reason has a lot to do with Connecticut’s irresponsibly low auto insurance coverage minimums which are as follows:

Here are the lowest CT Auto Insurance Policies:

1. $20,000 for injury to or death of a person,

2. $40,000 for injury to or death of more than one person in any accident, and

3. $10,000 for property damage (CGS §§ 38a-335 and 14-112(a)).

To put this in context, let me tell you a story. A woman is driving her car. She’s in her lane. Suddenly a man who is texting crosses the centerline and hits her head on. She is very injured. Has multiple fractures in her legs and face. And she requires emergency surgery.  And she spends weeks in the hospital. Then there’s home rehabilitation.

And as is far too common, the guy who chose to snapchatting his girlfriend over the safety of us all – has only a state minimum policy of 20/40. And he has no other assets to attach. No house. No money in the bank. Nothing.

As a result, her husband has to take FMLA leave to care for her. He spends countless hours taking her to doctor’s appointments and doing the household tasks she used to do.

What is Loss of Consortium?

He has a claim for loss of consortium.  Loss of consortium is a suit by a spouse for the loss of the affection, dependence and companionship that he has suffered through the loss of his spouse. Damages for loss of consortium include both past and future loss. “Consortium” includes affection, society, companionship and physical intimacies of the spousal relationship. You can read more about loss of consortium claims here.

A 20/40 policy means the insurance company is limited to only having to pay out $20,000 per person and $40,000 per wreck. For example, if there was a passenger in the woman’s car the total insurance company would have to pay out is $40,000 – $20,000 to the driver and $20,000 to the passenger

Can the husband recover even though he was not in the car but suffered a compensable loss as a direct result of the driver choosing to violate road safety rules?

Will Insurance Cover?

The answer is a very unsatisfactory “no”.

A plaintiff asserting a claim for a loss of consortium cannot-recover an independent “per person” recovery under an automobile insurance policy due. Connecticut courts hold that this is a derivative claim. If you like reading such things, the leading Connecticut case on this issue is Izzo v. Colonial Penn Ins Co., 203 Conn. 305 (1987).

Most of all, you’ll notice if you read the case is that the limits in 1983 were 20/40. In the face of massive medical inflation over the past 33 years these minimal limits remain in place. Its profits over people.

Therefore, the amount of coverage available to both the injured person and her spouse is $20,000.

Further, the insurance companies limit their liability in their auto policies. The standard clause in the policy defining the “per person” liability limit as applicable to all damages arising from that person’s bodily injuries, also precludes such recovery.

In conclusion, this is nothing more than profits over people.

Contact me if you have been injured in a car wreck and have questions about your rights. I am only licensed to in Connecticut. (860) 471-8333 or send me an email:

Trial Presentation: Getting Evidence On A Screen

Attorney Andrew Garza and our court tech set up.
Attorney Andrew Garza and the CT Trial FIrm, LLC court tech set up.

We’re often asked how we do it. How to get your documents on a screen in court? How to display video in court? How to show pictures to a jury? This post is about trial presentation: getting evidence on a screen.

We’re often asked about our trial presentation process. Here’s our secret sauce.

Epson EX3240 SVGA 3LCD Projector 3200  

We tried several projectors. The Epson EX3240 was the best value/quality play that we found. It’s listed on Amazon right now for $399. It has no problem displaying images, videos and documents in courtroom lighting. None.

AmazonBasics High-Speed HDMI Cable – 25 Feet

I love wireless setups. I don’t trust wireless set ups for court presentations. Hardwire me, baby. One less thing to go wrong. At $10.69 on Amazon this 25 foot HDMI cable is both a bargain and a must have.

Epson Duet 80-Inch Dual Aspect Ratio Projection Screen

You need a big screen. Don’t make your fact finder squint. This screen is fantastic. It is adjustable. It is easy to carry. Fairly lightweight. And solid construction. A must have.

And get a stand for your projector. This can be a small portable table or a tripod.

If You Are Using An IPad and You Should

The ipad is a fantastic trial presentation tool. Better than my laptop. Here’s why. The Trial Pad app is outstanding. It is the best presentation software that I have used. I strongly recommend the iPad Pro. The extra screen size and RAM make it even more useful. Also the extended battery on the Pro will keep your presentation going.

Assuming you are using an iPad you’ll need these things:

Lightning Digital AV Adapter

This $49 adapter allows you to connect your iPad to the projector via HDMI. At $49 it is a ripoff. But it is necessary,

Trial Pad

This app is just the best. I’ve used others. I’m not going to waste space in this post writing about it. Click on the link above. See what it does. Buy it. Use it. Love it.

Odds and Ends

Get a long extension cord. You’ll never know where the outlets are going to be.

Get a power strip. You’ll want to make sure you can plug in and charge your devices.

Get a big solid tote bag. You’ll need it for all of your cords, power strips, and projector. Basically buy the biggest and most solid tote bag you can find.

And the backbone of all of this is having a paperless office. Click here to learn how to go paperless.