Mark Brault et al v. Connecticut Department of Energy and Environmental Protection

District Court, D. Connecticut·Decided July 30, 2026·No. 3:23-cv-00696·Unknown

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT MARK BRAULT ET AL, : Plaintiffs, : : v. : Civil No. 3:23-cv-696-OAW : CONNECTICUT DEPARTMENT : OF ENERGY AND ENVIRONMENTAL : PROTECTION, : Defendant. : RULING ON DEFENDANT’S MOTION TO DISMISS Plaintiffs, Mark Brault and Carol Brault, accuse Defendant, Connecticut’s Department of Energy and Environmental Protection (hereinafter, “DEEP”), of surveilling their property without a warrant to do so, thereby depriving them of their rights under the Fourth and Fourteenth Amendments to the United States Constitution in violation of 42 U.S.C. § 1983 (hereinafter, “Section 1983”). ECF No. 1, ¶¶ 1–3, 10. Specifically, their Complaint alleges that DEEP equipped a bear with a camera and allowed such bear to roam Plaintiffs’ property while unwittingly recording and transmitting footage to DEEP. Id., ¶¶ 6–9. Defendants move the court to dismiss the Complaint in its entirety, pursuant to Rule 12(b)(1) or Rule 12(b)(6) of the Federal Rules of Civil Procedure. ECF No. 10, at 1. The court carefully has reviewed the Motion to Dismiss, the parties’ memoranda of law, and the broader record in this action. See, e.g., ECF Nos. 1, 10, 10-1, 14, 15. For the following reasons, the court GRANTS the Motion.

I. BACKGROUND The following allegations are taken from the Complaint and certain “public records that are integral to the underlying facts.” Errato v. Bendett & McHugh, PC, No. 3:23-CV- 1674 (OAW), 2025 WL 1475508, at *1 (D. Conn. May 21, 2025) (providing that courts may “‘take judicial notice’” of such records when considering motions to dismiss) (quoting Roth v. Jennings, 489 F.3d 499, 509 (2d Cir. 2007)).

A. Defendant DEEP is an agency of the State of Connecticut. ECF Nos. 1, ¶ 3; 10, at 1. Among other things, it “regularly captures bears and places collars on them for the purpose of tracking the bears and studying their habits.” Hartland v. Brault, No. LLI-CV21-6026840- S, Docket No. 140, at 17 (Conn. Super. Aug. 23, 2023); see also ECF No. 10-1, at 2.

B. Plaintiffs Plaintiffs are residents of Hartland, Connecticut, where they own and reside upon

a 114-acre parcel of thickly-forested land (hereinafter, the “Property”). ECF No. 1, ¶¶ 4– 5. Until recently, they also operated a business on the Property, whereby they “offered customers wildlife and nature tours, indulging the opportunity to view and photograph bears.” Hartland v. Brault, No. LLI-CV21-6026840-S, Docket No. 140, at 2–3 (Conn. Super. Aug. 23, 2023). In October 2020, Mr. Brault “was recorded on a [DEEP] video feeding two bear cubs” on the Property. Id. at 3–4. Hartland subsequently sought an injunction against him in state court, see id. at 1, and, in August 2023, such court (The Hon. John D. Moore) “permanently enjoin[ed]” him from “intentionally feeding bears,” see id. at 19–20 (citing, as evidence of Mr. Brault’s intentional bear-feeding, “the frequent examples of [his] proximity to bears” on the Property and “the contrast in the concentration of bear activity reflected in the ‘bear-ping’ maps” provided by DEEP).1

C. The Instant Action

Plaintiffs accuse DEEP of having affixed a collar containing a hidden camera to a particular bear, Bear Number 119, for the purpose of surveilling Plaintiffs. ECF No. 1, ¶¶ 7–8. The Complaint alleges that, on May 20, 2023, Bear Number 119 wandered onto the Property and “approached to within 200 yards” of Plaintiffs’ home while “taking and transmitting pictures of video” to DEEP. Id., ¶ 8; see also id. at 7–9 (providing, as evidence of such allegations, photographs of Bear Number 119 wearing a collar).2 Because DEEP did not have a warrant to surveille the Property, Plaintiffs claim that DEEP deprived them of their Fourth and Fourteenth Amendment rights in violation of Section 1983—and they ask the court to issue an injunction “requiring [DEEP] immediately to

remove and disable the cameras from all tagged bears within ten miles” of the Property, “destroy” all evidence gathered by Bear Number 119, and “cease and desist” all warrantless surveillance of the Property. Id., ¶¶ 9–10. In response, Defendant asks the court to dismiss the Complaint in its entirety, pursuant to Rule 12(b)(1) or Rule 12(b)(6). ECF No. 10, at 1.

1 It is worth noting that Judge Moore also concluded that Mr. Brault’s “knowledge of and obvious love for the natural world is commendable, and even, daresay the court, inspirational.” Hartland v. Brault, No. LLI-CV21-6026840-S, Docket No. 140, at 18 (Conn. Super. Aug. 23, 2023). Additionally, Judge Moore found “no persuasive evidence implicating Carol Brault . . . in intentional bear feeding.” Id. a 19. 2 While not part of the record, and while it does not impact the court’s ruling in this case, there is publicly- available indicia that DEEP indeed has affixed video cameras on certain bears. See, e.g., https://www. youtube.com/shorts/O2NC53PuCnQ (last visited July 15, 2026). II. LEGAL STANDARD To survive dismissal under Rule 12(b)(1), a plaintiff must establish “by a preponderance of the evidence that subject matter jurisdiction exists.” Makarova v. United States, 201 F.3d 110, 113 (2d Cir. 2000). The court must “‘take all uncontroverted facts in the complaint . . . as true, and draw all reasonable inferences in favor of the party

asserting jurisdiction.’” Schaap v. United States, No. 3:23-CV-895 (OAW), 2025 WL 2379262, at *2 (D. Conn. Aug. 15, 2025) (quoting Tandon v. Captain’s Cove Marina of Bridgeport, Inc., 752 F.3d 239, 243 (2d Cir. 2014)). Nevertheless, if the court deems that it “lacks the statutory or constitutional power to adjudicate” a claim, it must dismiss it. Makarova, 201 F.3d at 113. To survive dismissal under Rule 12(b)(6), “a complaint must contain sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007)); see also Fed. R. Civ. P. 8(a)(2) (requiring “a short and plain statement

of the claim showing that the pleader is entitled to relief”). “A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Iqbal, 556 U.S. at 570. The court must draw all reasonable inferences in the plaintiff’s favor. Roth v. Jennings, 489 F.3d 499, 503 (2d Cir. 2007). However, “[t]hreadbare recitals of the elements of a cause of action, supported by mere conclusory statements, [will] not suffice.”3 Iqbal, 556 U.S. at 678.

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Mark Brault et al v. Connecticut Department of Energy and Environmental Protection, (D. Conn. 2026).

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