Justia Connecticut Supreme Court Opinion Summaries

Plaintiffs were employees of Employers when they each suffered compensable injuries. Plaintiffs were treated at two different hospitals. In each case, the hospital submitted a bill for its services to Employer. Employer paid each hospital in accordance with the cost assessment of a third-party bill reviewer, which in each case was significantly less than what had been billed by the hospital. The hospitals subsequently sought to have the workers’ compensation commissioner determine Employer’s liability for the hospital costs. At issue was whether Employer’s liability for the hospital services should be assessed on the basis of the commissioner’s determination of what it “actually cost” the hospitals to render the services, as provided under Conn. Gen. Stat. 31-294d(d), or on the basis of the hospitals’ published rates that they are required to charge “any payer” under Conn. Gen. Stat. 19a-646. The commissioner concluded that the two cases were controlled by Burge v. Stonington, in which the Supreme Court concluded that the “actually costs” language in the predecessor to section 31-294d(d) had been repealed or preempted in 1973 when the legislature first regulated hospital rates. The Supreme Court affirmed, holding that the public health scheme governing hospital rates for payers generally controlled the cases here. View "Caraballo v. Elec. Boat Corp." on Justia Law

The named plaintiff in this putative class action and her daughter (together, Plaintiffs) were injured in motor vehicle accidents. Defendant, which administered the Medicaid program for the state and was the designated assignee of the Department of Social Services under Conn. Gen. Stat. 17b-265, paid for the medical care that Plaintiffs received as a result of their injuries. After Plaintiffs brought civil actions against the tortfeasors, Defendant, acting through its agent, sought to recover from Plaintiffs the amounts they recovered from the tortfeasors as reimbursement for the payments made by Defendant for Plaintiffs’ medical care. Plaintiffs brought this action seeking, inter alia, a declaratory judgment that section 17b-265 did not authorize Defendant to seek reimbursement from them but required Defendant to seek recovery directly from the liable third parties. The trial court granted summary judgment for Defendant. The Appellate Court affirmed. The Supreme Court affirmed, holding that the Appellate Court did not err in concluding that section 17b-265 permitted Defendant to seek reimbursement from Plaintiffs and other similarly situated persons for amounts that they recover from liable third parities for medical costs. View "Rathbun v. Health Net of the Northeast, Inc." on Justia Law

Plaintiff, who worked for United Parcel Service, Inc. (UPS) for thirty-two years, was diagnosed with diabetes in 1987 and with diabetic neuropathy in 1998. The diabetic neuropathy caused impairment to his arms and hands. In 2003, Plaintiff suffered injuries to his upper arms and hands in a work-related accident. After Plaintiff retired in 2008 he filed a claim for benefits. The Workers’ Compensation Commissioner apportioned the payment so that Defendants, UPS and its insurer, paid only for the proportion of disability attributed to Plaintiff’s occupational injuries rather than pay the entirety of Plaintiff’s permanent partial disability to his upper extremities and hands. The Workers’ Compensation Board affirmed. The Appellate Court reversed. The Supreme Court affirmed, holding that a disability arising from a progressive nonoccupational condition - such as Plaintiff’s diabetes and diabetic neuropathy - that manifests prior to an occupational injury and that further disables the same body part is a compensable preexisting injury rather than a noncompensable concurrently developing disease under the apportionment rule established in Deschenes v. Transco, Inc. View "Sullins v. United Parcel Serv., Inc." on Justia Law

Plaintiffs, insurance producers who conduct business within the state and licensees of the Department of Insurance (department), filed a declaratory judgment action against the Commissioner of Insurance seeking declaratory rulings with respect to the legality of their conduct in the sale of life insurance policies. The trial court dismissed the action, concluding (1) Plaintiffs failed to exhaust their administrative remedies before bringing this declaratory judgment action pursuant to Conn. Gen. Stat. 4-175; and (2) Plaintiffs failed to establish their standing to bring this declaratory judgment action. The Supreme Court reversed, holding (1) the trial court improperly determined that Plaintiffs were not aggrieved parties with standing to bring this declaratory judgment action; and (2) the trial court improperly dismissed this declaratory judgment action on the ground that Plaintiffs had failed to exhaust their administrative remedies. View "Fin. Consulting, LLC v. Comm’r of Ins." on Justia Law

The Department of Environmental Protection (Department), acting through its office of Long Island Sound Programs (Office), ordered Plaintiffs, Gail and Thomas Lane, to remove a boardwalk and dock from their property because they had been installed without the statutorily required permits. The Office then denied Plaintiffs’ application for a certificate of permission to retain and maintain the structures and to install a new boardwalk pursuant to Conn. Gen. Stat. 22a-363b(a)(2). The Department upheld the Office’s rulings. The trial court dismissed Plaintiffs’ administrative appeal. The Appellate Court affirmed. The Supreme Court affirmed, holding that the Appellate Court properly interpreted section 22a-363b(a) in concluding that the trial court properly dismissed Plaintiffs’ administrative appeal. View "Lane v. Comm’r of Envtl. Prot." on Justia Law

Plaintiff property owner sent a letter to a zoning enforcement officer for the Town of Darien, asserting that permits obtained by her adjoining neighbor had been illegally issued. Plaintiff received no response to that letter. Plaintiff filed an application to appeal. The town zoning board of appeals dismissed Plaintiff’s application for lack of a timely appeal and lack of a “decision” from which an appeal could lie. The trial court dismissed Plaintiff’s appeal from the decision of the board, concluding that substantial evidence supported the board’s determination that the town zoning enforcement officer did not make a decision that could be appealed. Plaintiff appealed, contending that the zoning enforcement officer rendered a decision that could be appealed either because (1) he actually made a determination regarding the merit of the violations alleged in her letter that he declined to communicate, or (2) because town zoning regulations obligated him to respond to or act upon the illegality alleged in Plaintiff's letter. The Supreme Court affirmed, holding that the zoning enforcement officer’s action or inaction with respect to Plaintiff’s letter did not give rise to an independent “decision” from which an appeal to the board would lie.View "Reardon v. Zoning Bd. of Appeals" on Justia Law

Plaintiff sought compensation for injuries he sustained while employed with his employer. The employer’s insurer at the time Plaintiff filed his claim entered into a voluntary agreement on the claim and subsequently sought apportionment against Employer’s prior insurers, including Republic-Franklin Insurance Company. Republic-Franklin did not agree to its apportionment liability until just before the close of evidence. Thereafter, the Workers’ Compensation Commissioner ordered Republic-Franklin to pay interest pursuant to Conn. Gen. Stat. 31-299b. The Workers’ Compensation Commission affirmed. The Supreme Court affirmed the decision of the Board, holding that the Commissioner’s order of interest was proper because (1) the Commissioner satisfied the statutory prerequisites of section 31-299b; and (2) Republic-Franklin failed to preserve its claim that the Commissioner’s order of interest was not made within a reasonable period of time as required by section 31-299b. View "Ferraro v. Ridgefield European Motors, Inc." on Justia Law

BNE Energy, Inc. submitted two petitions for declaratory rulings seeking the Connecticut Siting Council’s approval for the construction and operation of three electric generating wind turbines on two separate properties in the town of Colebrook. Plaintiffs intervened in the proceedings. The Council approved the petitions with conditions, and Plaintiffs appealed. The trial court dismissed Plaintiffs’ appeals. The Supreme Court affirmed, holding that the trial court did not err in concluding that the Council (1) had jurisdiction over BNE’s petitions; (2) was authorized to attach conditions to its approval of the petitions; (3) was authorized to approve the petitions even though it had not determined that the proposed projects comply with state noise law; (4) properly approved of shorter hub heights for one of the projects; and (5) did not deprive Plaintiffs of their right to fundamental fairness during the hearings on the petitions. View "FairwindCT, Inc. v. Conn. Siting Council" on Justia Law

After a malpractice action was filed against a physician licensed by the Commissioner of Public Health (Department), the Department and the physician entered into a consent order, designated as a public document, indicating that the physician had agreed to a reprimand on his license and a civil penalty. A newspaper (Newspaper) subsequently made a request to the Department under the Freedom of Information Act (Act) for the records reviewed by a consultant in connection the Department’s investigation into the case, including an exhibit (exhibit A). After the Department failed to produce exhibit A, the Newspaper filed a complaint with the Freedom of Information Commission (Commission). The Department argued before the Commission that exhibit A contained Practitioner Data Bank and Healthcare Data Bank records and that federal law provided a basis to withhold those records. The Commission concluded (1) federal regulations barred disclosure of records received from the Healthcare Data Bank, but (2) regulations did not bar disclosure of records received from the Practitioner Data Bank. The superior court affirmed. The Supreme Court reversed in part, holding that none of the records were not subject to public disclosure under the Act.View "Comm’r of Pub. Health v. Freedom of Info. Comm’n" on Justia Law

The Connecticut Siting Council approved a proposed project of the Connecticut Light and Power Company. Plaintiffs appealed the siting counsel’s decision while the power company’s motion for reconsideration of the decision, with regard to the denial of a second project, was still pending. The siting council subsequently granted the motion for reconsideration and approved the second project. The trial court dismissed Plaintiffs’ appeal. The appellate court affirmed, concluding that the trial court lacked subject matter jurisdiction because Plaintiffs had not appealed from a final decision of the siting council. The Supreme Court affirmed, holding that the appellate court did not err in its judgment.View "Citizens Against Overhead Power Line Constr. v. Conn. Siting Council" on Justia Law