Justia Connecticut Supreme Court Opinion Summaries

Two licensed wrecker services in Connecticut were summoned by state police to remove a severely damaged tractor trailer from a highway accident. The wrecker services used specialized equipment, including a costly rotator truck, to recover and tow the vehicle, then transported it to their storage facility. They sent an itemized invoice to the vehicle owner’s insurer, which included charges for the use of special equipment and supervisory personnel. The insurer paid the invoice under protest and subsequently filed a complaint with the Commissioner of Motor Vehicles, arguing that the charges were excessive and not permitted under state regulations.A Department of Motor Vehicles hearing officer determined that the wrecker services had overcharged for their nonconsensual towing services by using their own rate schedule based on equipment rather than the hourly labor rate set by the commissioner. Most equipment-based charges were disallowed, and the wrecker services were ordered to pay restitution and a civil penalty. The Superior Court dismissed the wrecker services’ administrative appeal, finding the hearing officer’s conclusions supported by substantial evidence. The Appellate Court affirmed, holding that the regulations required fees for exceptional services to be based solely on the hourly labor rate, excluding equipment costs.The Connecticut Supreme Court reviewed the case and concluded that the relevant regulation, § 14-63-36c (c), was ambiguous and could reasonably be interpreted to allow wrecker services to charge additional fees for exceptional services, including costs associated with special equipment, provided those fees are itemized and posted in accordance with regulatory requirements. The Court held that prohibiting such charges would prevent wrecker services from recouping necessary costs and could undermine the availability of exceptional towing services. The Supreme Court reversed the Appellate Court’s judgment in part and remanded the case for further proceedings consistent with its interpretation. View "Modzelewski's Towing & Storage, Inc. v. Commissioner of Motor Vehicles" on Justia Law

A four-year-old child drowned after wandering unattended from the home where she had been placed under temporary custody by order of the Probate Court. The child’s parents had previously lost guardianship, and the court had vested temporary custody in maternal relatives. To determine whether to grant a full transfer of guardianship, the Probate Court ordered the Department of Children and Families (DCF) to investigate the home and report its findings. DCF submitted its report, recommending the placement, but before the court could hold a hearing on permanent guardianship, the child died. The child’s estate, through her father as administrator, alleged that DCF’s negligence in investigating the placement and in making recommendations to the Probate Court was a proximate cause of the child’s death, and also claimed DCF failed to fulfill independent duties to protect the child from abuse and neglect.After the estate received permission from the Claims Commissioner to sue the state, DCF moved to dismiss the action in the Superior Court, arguing that it was entitled to absolute quasi-judicial immunity for actions integral to the judicial process, such as conducting court-ordered investigations and making recommendations. The Superior Court agreed, holding that DCF was protected by absolute quasi-judicial immunity when acting as an arm of the Probate Court, and that the Claims Commissioner could not waive this immunity. The court dismissed the action, finding the complaint’s allegations insufficient to overcome DCF’s immunity.On appeal, the Connecticut Supreme Court held that the Claims Commissioner’s waiver of sovereign immunity under the relevant statute does not preclude the state from asserting absolute quasi-judicial immunity. However, the Court reversed in part, concluding that some of the estate’s allegations may fall outside the scope of quasi-judicial immunity, particularly those involving DCF’s independent statutory duties. The case was remanded for further proceedings to determine which claims, if any, are not barred by quasi-judicial immunity. View "Jamie G. v. Dept. of Children & Families" on Justia Law

A nonprofit substance abuse treatment facility in Kent, Connecticut, challenged the state’s approval of a competitor’s application to establish a similar facility in the same town. The competitor, Birch Hill Recovery Center, LLC, applied for a certificate of need from the Department of Public Health. The plaintiff was granted intervenor status in the administrative proceedings, allowing it to participate in hearings and present evidence. After public hearings, a hearing officer recommended denying Birch Hill’s application, but the Department and Birch Hill later entered into a settlement agreement that approved the application with certain conditions.The plaintiff appealed the Department’s decision to the Superior Court, arguing that the approval was an abuse of discretion, especially given the hearing officer’s earlier recommendation. The defendants moved to dismiss the appeal, contending that the plaintiff was not aggrieved by the decision and thus lacked standing. The Superior Court initially dismissed the appeal on the ground that the settlement agreement was not a final decision. The Appellate Court affirmed this dismissal. However, the Connecticut Supreme Court later held that the settlement agreement was a final decision and remanded the case for further proceedings. On remand, the Superior Court again dismissed the appeal, this time concluding that the plaintiff was not statutorily or classically aggrieved and therefore lacked standing.The Supreme Court of Connecticut affirmed the dismissal, holding that the plaintiff was neither statutorily nor classically aggrieved by the Department’s decision. The Court explained that mere economic competition resulting from governmental action does not confer standing in administrative appeals unless the relevant statute expressly protects competitors’ interests. The Court found that the applicable statute, General Statutes (Rev. to 2017) § 19a-639 (a), did not create such an exception. The plaintiff’s status as an intervenor and its participation in the administrative process did not, by themselves, establish a specific, personal, and legal interest sufficient for standing. View "High Watch Recovery Center, Inc. v. Dept. of Public Health" on Justia Law

Aquarion Water Company of Connecticut (Aquarion) filed a rate application with the Public Utilities Regulatory Authority (PURA) in August 2022, seeking to increase its rates to cover approximately $700 million in capital improvements made since 2013. Aquarion also sought to recover $3 million in deferred water conservation expenses and $2.2 million for its employee incentive compensation program. PURA reviewed the application and allowed Aquarion to include $650 million in plant additions completed before August 31, 2022, in its rate base but excluded $48 million in post-application plant additions. PURA also denied Aquarion’s request for the full amount of deferred conservation expenses and employee incentive compensation, reducing the approved revenue requirement to $195 million and the return on equity (ROE) to 8.7%.The trial court dismissed Aquarion’s appeal, finding substantial evidence supporting PURA’s decisions. Aquarion then appealed to the Connecticut Supreme Court, arguing that PURA acted arbitrarily and capriciously in its prudence determinations and that the rate order was confiscatory.The Connecticut Supreme Court upheld PURA’s exclusion of the $42 million in post-application plant additions, finding a discernible difference in the quality of evidence submitted for pre- and post-application additions. The court also upheld the denial of $2.2 million for the employee incentive compensation program, agreeing that PURA did not use hindsight but rather assessed the program’s future efficacy based on historical data.However, the court found that PURA improperly used hindsight to evaluate the prudence of $1.5 million in deferred conservation expenses, focusing on after-the-fact economic savings rather than the prudence of the decision at the time the expenses were incurred. The court reversed this part of the trial court’s judgment and remanded the case for further proceedings.The court also rejected Aquarion’s claim that the rate order was confiscatory, affirming that the approved ROE of 8.7% was not effectively reduced by the disallowance of certain costs and was sufficient to maintain Aquarion’s financial integrity and ability to attract capital. View "Aquarion Water Co. of Connecticut v. Public Utilities Regulatory Authority" on Justia Law

A national consumer advocate law firm (C Co.) and its affiliate (S Co.) providing administrative support services sought injunctive and declaratory relief against the Department of Banking. The Department had initiated an administrative enforcement action against S Co. for allegedly engaging in unlicensed debt negotiation activities. The plaintiffs argued that S Co. was exempt from licensing requirements under a presumption established in a prior case (Persels & Associates, LLC v. Banking Commissioner), which holds that attorneys providing debt negotiation services as part of their legal practice fall under the exclusive regulation of the Judicial Branch.The trial court denied the Department's motion to dismiss the plaintiffs' action, concluding that the plaintiffs were not required to exhaust administrative remedies before seeking judicial intervention on whether the Persels presumption applied to S Co. The Department appealed, arguing that the Commissioner of Banking should first determine whether the presumption applied.The Supreme Court of Connecticut affirmed the trial court's decision, holding that the plaintiffs were not required to exhaust administrative remedies before seeking judicial intervention. The court reasoned that the Commissioner of Banking lacks the expertise to determine whether the Persels presumption applies, as this involves assessing whether the activities in question constitute the practice of law, which falls under the exclusive authority of the Judicial Branch. The court emphasized that allowing the commissioner to make this determination would violate the constitutional separation of powers. Therefore, the plaintiffs could seek declaratory and injunctive relief in the trial court without waiting for the commissioner to resolve the issue. View "Commonwealth Servicing Group, LLC v. Dept. of Banking" on Justia Law

The complainant, John Ward, filed a complaint with the Commission on Human Rights and Opportunities (CHRO) alleging that the City of Stamford discriminated against him based on his veteran status and disability. The CHRO found reasonable cause and certified the complaint to the Office of Public Hearings (OPH). During the public hearing, Ward moved to amend his complaint to include a claim for denial of reasonable accommodations. The human rights referee granted the motion over the city's objection.The city filed an interlocutory administrative appeal with the Superior Court, arguing that the CHRO lacked jurisdiction to hear the amended complaint without a reasonable cause finding. The CHRO and Ward moved to dismiss the appeal, contending that interlocutory rulings are not appealable under General Statutes § 46a-94a (a) and that the statutory requirements for an interlocutory appeal under § 4-183 (b) were not met. The trial court denied the motions to dismiss, finding that the referee's ruling was a final decision under § 4-183 (a).The Supreme Court of Connecticut reviewed the case and concluded that the referee's ruling was not a final decision under § 4-183 (a) because it did not terminate any aspect of the case or determine any rights or obligations. The court also determined that § 46a-94a (a) allows for interlocutory appeals under § 4-183 (b), but the city's appeal did not meet the criteria for such an appeal because postponement would not result in an inadequate remedy. The court reversed the trial court's decision and remanded with direction to grant the motions to dismiss the city's appeal. View "Stamford v. Commission on Human Rights& Opportunities" on Justia Law

The plaintiff, Larissa Marland, individually and as administratrix of the estate of Norman Marland, filed a medical malpractice claim against the University of Connecticut Health Center and related entities. The decedent had been treated at the hospital and was later admitted to the intensive care unit, where he fell and subsequently died. The plaintiff alleged that the hospital staff breached the standard of care owed to the decedent.The plaintiff filed a notice of claim with the claims commissioner, including a physician’s opinion letter. The claims commissioner failed to resolve the claim within the statutory two-year period and an additional one-year extension granted by the General Assembly. Despite this, the commissioner eventually authorized the plaintiff to sue the state. The plaintiff then filed the present action in the Superior Court.The state moved to dismiss the complaint, arguing that the claims commissioner’s waiver of sovereign immunity was invalid because it was issued after the expiration of the one-year extension. The trial court agreed and dismissed the case for lack of subject matter jurisdiction, concluding that the commissioner did not have the authority to grant the waiver beyond the extension period.The Supreme Court of Connecticut reviewed the case and concluded that the trial court improperly dismissed the plaintiff’s action. The court held that, once the claims commissioner authorizes suit and waives sovereign immunity, the state cannot challenge that decision in the Superior Court. The court emphasized that such challenges should be raised before the claims commissioner. The court reversed the trial court’s judgment and remanded the case with direction to deny the state’s motion to dismiss. View "Marland v. University of Connecticut Health Center" on Justia Law

The plaintiff, an electric distribution company, appealed from the trial court's dismissal of its consolidated administrative appeals from two final decisions by the Public Utilities Regulatory Authority (PURA). PURA had found the plaintiff violated statutory obligations related to emergency planning and storm recovery during an August 2020 tropical storm, intending to reduce the plaintiff's authorized return on equity (ROE) by fifteen basis points. Additionally, PURA imposed over $1.2 million in fines for violating storm performance standards and $61,000 in civil penalties for late reporting of minor accidents.The trial court dismissed the plaintiff's appeals, upholding PURA's decisions. The plaintiff then appealed to the higher court, challenging the ROE reduction, the fines for storm performance violations, and the penalties for late accident reporting. During the appeal, PURA decided not to implement the ROE reduction, rendering the issue moot. The court determined that neither the voluntary cessation nor the collateral consequences exceptions to the mootness doctrine applied. The court directed the vacatur of the portion of PURA's order authorizing the ROE reduction and the corresponding part of the trial court's judgment.Regarding the fines for late reporting of minor accidents, the court concluded that the failure to report a minor accident did not qualify as a "continued violation" under the statute. Instead, each monthly failure to report constituted a single, distinct violation. The case was remanded to the trial court to order PURA to recalculate the penalties accordingly.The court found sufficient evidence to support PURA's findings that the plaintiff violated storm performance standards by failing to provide a dedicated make safe crew for Bridgeport and inadequately communicating with city officials. The court affirmed the trial court's judgments in all other respects. View "United Illuminating Co. v. Public Utilities Regulatory Authority" on Justia Law

The case involves a dispute between a property owner and a city regarding the validity of a lien placed on the property. The property, an apartment building, was destroyed by arson, leading to the displacement of its tenants. The city incurred costs relocating the tenants and placed a lien on the property to recover these expenses under the Uniform Relocation Assistance Act (URAA).The trial court ruled in favor of the property owner, determining that the lien was invalid because the displacement was caused by a third party's arson, not by the city's enforcement of its building code. The court allowed the property owner to challenge the lien using an affirmative defense provided by the URAA, which is typically available only in civil actions brought by a municipality to recover relocation expenses.The Supreme Court of Connecticut reviewed the case and reversed the trial court's decision. The Supreme Court held that the tenants were "displaced persons" under the URAA because their displacement was a direct result of the city's enforcement of its building code, regardless of the arson being the initial cause. The court further held that the affirmative defense provided by the URAA, which allows a landlord to argue that the displacement was not due to their violation of housing codes, is only available in civil actions brought by the municipality and cannot be used to challenge a lien in an application to discharge it.The Supreme Court directed the trial court to deny the property owner's application to discharge the city's lien, thereby upholding the city's right to recover its relocation expenses through the lien. View "PPC Realty, LLC v. Hartford" on Justia Law

The plaintiffs, parents of minor children, challenged a public act that eliminated the religious exemption from vaccination requirements for school enrollment. They argued that the act violated their constitutional rights to free exercise of religion, equal protection, and a free public education, as well as their statutory rights under Connecticut law. The defendants, state and municipal officials, moved to dismiss the case on the grounds of sovereign immunity.The trial court denied the defendants' motions to dismiss, concluding that the plaintiffs' constitutional claims satisfied the substantial claim exception to sovereign immunity, and their statutory claim under Connecticut law satisfied the statutory waiver exception. The defendants appealed this decision.The Connecticut Supreme Court reviewed the case and determined that the trial court must assess the legal sufficiency of the plaintiffs' allegations to determine whether they have asserted a substantial claim of a constitutional violation. The court concluded that the plaintiffs' constitutional claims failed as a matter of law. The act was deemed a neutral law of general applicability, rationally related to the state's interest in protecting public health. The court also found that the act did not violate the plaintiffs' right to a free public education, as it imposed a reasonable vaccination requirement.However, the court agreed with the trial court that the plaintiffs' statutory free exercise claim under Connecticut law satisfied the statutory waiver exception to sovereign immunity. The court found that the scope of the waiver extended to free exercise challenges to the enforcement of legislation and that applying the statute to the public act did not violate any constitutional principles.The Connecticut Supreme Court reversed the trial court's decision in part, directing the dismissal of the constitutional claims, but affirmed the decision regarding the statutory claim, allowing it to proceed. View "Spillane v. Lamont" on Justia Law