Connecticut Light & Power Co. v. Public Utilities Regulatory Authority

CourtSupreme Court of Connecticut
DecidedApril 28, 2026
DocketSC21122
StatusPublished

This text of Connecticut Light & Power Co. v. Public Utilities Regulatory Authority (Connecticut Light & Power Co. v. Public Utilities Regulatory Authority) is published on Counsel Stack Legal Research, covering Supreme Court of Connecticut primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Connecticut Light & Power Co. v. Public Utilities Regulatory Authority, (Colo. 2026).

Opinion

************************************************ The “officially released” date that appears near the beginning of an opinion is the date the opinion will be published in the Connecticut Law Journal or the date it is released as a slip opinion. The operative date for the beginning of all time periods for the filing of postopinion motions and petitions for certification is the “officially released” date appearing in the opinion. All opinions are subject to modification and technical correction prior to official publication in the Connecti- cut Law Journal and subsequently in the Connecticut Reports or Connecticut Appellate Reports. In the event of discrepancies between the advance release version of an opinion and the version appearing in the Connecticut Law Journal and subsequently in the Connecticut Reports or Connecticut Appellate Reports, the latest version is to be considered authoritative. The syllabus and procedural history accompanying an opinion that appear in the Connecticut Law Journal and subsequently in the Connecticut Reports or Connecticut Appellate Reports are copyrighted by the Secretary of the State, State of Connecticut, and may not be reproduced or distributed without the express written permission of the Commission on Official Legal Publications, Judicial Branch, State of Connecticut. ************************************************ Connecticut Light & Power Co. v. Public Utilities Regulatory Authority

THE CONNECTICUT LIGHT AND POWER COMPANY v. PUBLIC UTILITIES REGULATORY AUTHORITY (SC 21122) McDonald, D’Auria, Ecker, Alexander and Bright, Js.

Syllabus

Pursuant to the Uniform Administrative Procedure Act (§ 4-166 (5) (A)), a “final decision” is “the agency determination in a contested case,” and a “contested case,” pursuant to § 4-166 (4), is “a proceeding . . . in which the legal rights, duties or privileges of a party are required by state statute or regulation to be determined by an agency after an opportunity for hearing or in which a hearing is in fact held . . . .”

The plaintiff electric supplier, C Co., appealed from the judgment of the trial court, which had dismissed its administrative appeal from the decision of the defendant, the Public Utilities Regulatory Authority (PURA), in connection with PURA’s investigation into C Co.’s response to an accident in the town of Norfolk. Downed electrical wires had entrapped the occupants of a vehicle that struck a utility pole owned and maintained by C Co., and, before first responders could rescue the occupants, they had to wait for approximately one hour until C Co.’s response specialist arrived at the scene and confirmed that certain electrical wires were de-energized. PURA thereafter issued a notice of proceeding, announcing that it was initiating an investigation into C Co.’s response to the accident. Following a hearing, at which C Co. participated, PURA issued its decision. PURA found that C Co.’s response to the accident had been imprudent and ordered C Co. to adopt a target response time of thirty minutes for certain life-threatening situations or “priority 1 events,” including situations in which live wires on vehicles prevent first responders from performing rescue efforts. In dismissing C Co.’s administrative appeal, the trial court determined that it lacked subject matter jurisdiction because PURA’s decision was not appealable under the provision (§ 4-183 (a)) of the Uniform Administrative Procedure Act allowing appeals from final agency decisions insofar as PURA’s imprudence finding and target response time order were not determinations made in a “contested case” for purposes of § 4-166 (4). On appeal to this court, C Co. claimed that the trial court had incorrectly concluded that it lacked jurisdiction over its administrative appeal. Held:

The trial court properly dismissed C Co.’s administrative appeal from PURA’s decision rendered in connection with its investigation into the accident for lack of subject matter jurisdiction, as that proceeding was not a “contested case” entitled to judicial review under § 4-183 (a) insofar as no state statute or regulation required PURA to determine C Co.’s rights, privileges, or duties after an opportunity for a hearing within the meaning of § 4-166 (4).

Neither of the statutes (§§ 16-14 and 16-18) on which C Co. relied in support of its claim that PURA was required to hold a hearing and to conduct the Connecticut Light & Power Co. v. Public Utilities Regulatory Authority

proceeding as a contested case was applicable to the imprudence finding or the order regarding target response time that C Co. was challenging on appeal.

With respect to § 16-14, which requires PURA to hold a hearing on any writ- ten “complaint” made by a town of “conditions resulting in [certain types of property damage] by electrolysis or by reason of the escape of electricity of any public service company,” even if certain letters submitted to C Co. by the local fire chief and the chief of service of the local ambulance service constituted written complaints to PURA within the meaning of that statute, those letters did not allege the type of property damage contemplated by § 16-14 but, rather, focused exclusively on C Co.’s response to the accident and the potential harm that C Co.’s response time had on the occupants trapped inside the vehicle.

Moreover, although § 16-14 also allows PURA to issue such orders “as may be necessary to prevent” the type of property damage contemplated by that statute, PURA explained in its final decision that the reason for imposing the thirty minute target response time was “to better protect public safety,” not to prevent the sort of property damage that § 16-14 is intended to address, and, accordingly, PURA did not and could not have relied on § 16-14 as authority for issuing the response time order.

With respect to § 16-18, which authorizes PURA, after a public hearing, to require public service companies to move or consolidate their utility poles or wires along public highways when required by public convenience or necessity, PURA did not order the relocation or consolidation of any poles or wires, and the focus of its investigation was on C Co.’s response to and reporting of the accident, not the relocation or consolidation of utility infrastructure.

Furthermore, it was of no consequence that, in its notice of proceeding, PURA relied on §§ 16-14 and 16-18 as authority for initiating the investi- gation into the accident and convening the hearing, as the relevant inquiry for determining contested case status is not whether PURA noticed the proceeding pursuant to statutes requiring a contested hearing but whether the agency determinations and orders that C Co. challenged in its admin- istrative appeal were required by state statute or regulation to be made or issued after a hearing.

To the extent that PURA, following the hearing, issued orders or made findings for which a hearing was not required, the hearing was gratuitous as to those orders and findings, and, when PURA conducts a hearing and the resulting decision includes both determinations that it was required by statute or regulation to make only after a contested hearing and other determinations that the law permitted it to make without any hearing, the mere fact that PURA addressed both sets of issues in a single proceeding does not convert every resulting determination into an appealable decision in a contested case.

C Co. could not prevail on its claim that PURA’s own regulations (§§ 16-1- 116 and 16-1-117) required PURA to conduct the underlying proceeding as a contested case. Connecticut Light & Power Co. v. Public Utilities Regulatory Authority

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Connecticut Light & Power Co. v. Public Utilities Regulatory Authority, Counsel Stack Legal Research, https://law.counselstack.com/opinion/connecticut-light-power-co-v-public-utilities-regulatory-authority-conn-2026.