Justia Government & Administrative Law Opinion Summaries

Connecticut Energy Marketers Association brought this action against the Department of Energy and Environmental Protection and the Public Utilities Regulatory Authority (collectively, Defendants) alleging that Defendants violated the Environmental Policy Act when Defendants approved a plan for a significant expansion of the use of natural gas in the state without evaluating the environmental impact of an increase in the use of natural gas pursuant to Conn. Gen. Stat. 22a-1b(c). Defendants filed separate motions to dismiss, arguing that no environmental impact evaluation was required because Defendants’ activities did not constitute “actions which may significantly affect the environment” for purposes of section 22a-1b(c). The trial court agreed and dismissed the complaint. The Supreme Court affirmed, holding that the trial court did not err in granting Defendants’ motions to dismiss on the ground that the requirement of an environmental impact evaluation in section 22a-1b(c) does not apply to Defendants’ activities in this case. View "Connecticut Energy Marketers Ass’n v. Department of Energy & Environmental Protection" on Justia Law

Plaintiffs requested from the Commissioner of Revenue Services a tax refund for the taxable years 2002, 2006, and 2007. The Commissioner denied the request. The trial court upheld the decision of the Commissioner. The Supreme Court (1) reversed the trial court’s award of summary judgment with respect to the taxable year 2002, holding that the form of the trial court’s judgment with respect to that claim was improper; but (2) affirmed the judgment of the trial court in all other respects, holding that the remainder of Plaintiffs’ contentions regarding the judgment were unavailing. View "Allen v. Commissioner of Revenue Services" on Justia Law

Petitioner was charged with several criminal offenses. Petitioner pleaded not guilty by reason of mental disease or defect. After a nonadversarial proceeding, the court rendered a judgment acquitting Petitioner of all offenses on the basis of mental disease or defect and committed Petitioner to the custody of the Commissioner of Mental Health and Addiction Services (Respondent) for a period not to exceed twenty-five years. Respondent later transferred custody of Petitioner to the jurisdiction of the Psychiatric Security Review Board. Petitioner remained committed to the custody of the Board for more than twenty-five years. Petitioner then filed a petition for habeas corpus challenging his extended confinement. The habeas court denied Petitioner’s petition. The Supreme Court affirmed, holding (1) the habeas court properly denied Petitioner relief on his claim regarding the knowing and voluntary nature of his plea; and (2) the habeas court correctly determined that Petitioner did not receive ineffective assistance of counsel. View "Dyous v. Commissioner of Mental Health & Addiction Services" on Justia Law

Plaintiffs were four bus companies operating buses over routes in and around the cities of New Britian and Hartford. Each plaintiff had authority to operate a bus service over a specific route pursuant to a certificate of public convenience and necessity. When a new busway was constructed by the state, the state sought to hire new companies to operate buses over the routes Plaintiffs currently operate. In a separate action, Plaintiffs sought to enjoin the Commissioner of Transportation from transferring the routes at issue to new operators. While that case was pending, the Commissioner condemned the certificates pursuant to the State’s power of eminent domain. Plaintiff filed the actions that were the subject of this appeal, claiming that the Commissioner lacked the statutory authority to condemn their certificates. The trial court consolidated the actions and granted the Commissioner’s motion for summary judgment, concluding that Conn. Gen. Stat. 13b-36(a) gave the Commissioner authority to condemn the certificates. The Supreme Court reversed, holding that the legislature did not intend for the term “facilities” in the statute to refer to intangible operating rights reflected in the certificates at issue. View "Dattco, Inc. v. Commissioner of Transportation" on Justia Law

Plaintiff was employed as a police officer by Defendant when he was injured. The Workers’ Compensation Commissioner dismissed Plaintiff’s claim for Workers’ Compensation benefits, concluding that Plaintiff had not departed his “place of abode” for duty as a police officer at the time he sustained his injury, and therefore, the incident was not compensable. The Workers’ Compensation Board affirmed. The Supreme Court reversed, holding that Plaintiff was acting “in the course of his employment” at the time he was injured, and therefore, the Board erred in affirming the Commissioner’s decision to dismiss Plaintiff’s claim. View "Balloli v. New Haven Police Department" on Justia Law

Plaintiff, the owner of a parcel of land in the Town of Colchester, challenged the Town’s assessment of the property for the tax year 2011. The Colchester Board of Assessment Appeals upheld the Town’s original valuation. Plaintiff appealed, arguing that the Town had used an improper method for valuing the property. The trial court upheld the Town’s original assessment, determining that Plaintiff had not established that it was aggrieved by the Town’s valuation because it found that Plaintiff’s expert was not credible. Plaintiff appealed, arguing that the trial court applied the incorrect legal standard of valuation to the subject property. The Supreme Court affirmed, holding that the trial court’s determination that Plaintiff failed to establish aggrievement was not clearly erroneous, and the trial court properly rejected Plaintiff’s appeal. View "Nutmeg Housing Development Corp. v. Colchester" on Justia Law

In 2006, Plaintiff’s decedent filed notices of claim with the Workers’ Compensation Commission. The Commission assigned the decedent’s claims to its asbestos docket for adjudication. After the decedent died, Plaintiff, his widow, filed a claim for dependent benefits that was joined with the original claims. The Connecticut Insurance Guaranty Association became a defendant in the proceedings. The Association was originally dismissed from the case for lack of exposure. The Commissioner later reinstated the Association as a party to the proceedings. The Workers’ Compensation Review Board affirmed. The Supreme Court affirmed the Board’s decision, holding that the Commissioner properly reinstated the Association as a party to the proceedings because the Commissioner’s broad case management authority permitted him to render a dismissal that was provisional, rather than final, in nature. View "Graham v. Olson Wood Associates, Inc." on Justia Law

Plaintiff filed a complaint against the Commissioner of Environmental Protection (Commissioner) and Dominion Nuclear Connecticut, Inc. (Dominion) alleging that the operation of the Millstone Nuclear Power Station owned and operated by Dominion was causing unreasonable pollution of the state’s waters in violation of the Connecticut Environmental Protection Act of 1971. The trial court dismissed the complaint on the ground that Plaintiff lacked standing. The Supreme Court reversed, concluding that Plaintiff had standing to bring her action under Conn. Gen. Stat. 22a-16. The Court ordered the trial court to conduct a hearing to determine whether the pending administrative permit renewal proceeding for the nuclear power station’s operation was inadequate to protect the rights recognized by the Act. The administrative proceeding then terminated when the Commissioner issued a renewal permit for Millstone. The trial court granted Defendants’ motions to dismiss, concluding that Plaintiff’s action was moot. The Supreme Court reversed, holding that Plaintiff’s claims were not moot because a determination that the renewal proceeding was inadequate to protect the rights recognized under the Act could result in the invalidation of the permit under which Millstone is currently operating. View "Burton v. Commissioner of Environmental Protection" on Justia Law

In 1996, Plaintiff was hired by Defendant, the New Haven Police Department, as a police officer. In 2011, Plaintiff suffered a myocardial infarction. Plaintiff later filed a claim for benefits under Conn. Gen. Stat. 7-433c(a) for hypertension and heart disease. The Workers’ Compensation Commissioner dismissed Plaintiff’s claim for benefits related to his hypertension as untimely but granted his claim for benefits related to his heart disease and myocardial infarction. The Workers’ Compensation Review Board affirmed. Defendant appealed, arguing that the Board improperly affirmed the Commissioner’s decision that Plaintiff’s hypertension and heart disease were separate diseases, each with its own limitation period for filing a claim for benefits. The Supreme Court affirmed, holding (1) the medical evidence supported the Board’s conclusion that Plaintiff’s hypertension and heart disease were separate medical conditions; and (2) the Board properly affirmed the Commissioner’s decision granting Plaintiff benefits pursuant to section 7-433c related to heart disease. View "Holston v. New Haven Police Department" on Justia Law

James Rock (the decedent) was employed by the University of Connecticut for more than thirty-five years before he died from a form of cancer that can be caused by occupational exposure to asbestos. The decedent never filed a notice of claim for workers’ compensation benefits. Plaintiff, the Estate of James Rock, filed a notice of claim for workers’ compensation benefits on behalf of the decedent. The Workers’ Compensation Commissioner dismissed Plaintiff’s claim for benefits for lack of standing. The Compensation Review Board upheld the dismissal but remanded the case to allow Plaintiff to advance a claim for burial expenses, lost wages the decedent sustained between his injury and his death, and medical expenses attributable to a compensable injury. The Supreme Court reversed in part, holding that an estate is not a legal entity capable of advancing a claim for any form of workers’ compensation benefits, and therefore, Plaintiff did not have standing to pursue any type of workers’ compensation benefits. View "Estate of Rock v. Univ. of Conn." on Justia Law