Paucatuck Eastern Pequot Indians v. Connecticut Indian Affairs Council

555 A.2d 1003, 18 Conn. App. 4, 1989 Conn. App. LEXIS 78
CourtConnecticut Appellate Court
DecidedMarch 28, 1989
Docket6292
StatusPublished
Cited by11 cases

This text of 555 A.2d 1003 (Paucatuck Eastern Pequot Indians v. Connecticut Indian Affairs Council) is published on Counsel Stack Legal Research, covering Connecticut Appellate Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Paucatuck Eastern Pequot Indians v. Connecticut Indian Affairs Council, 555 A.2d 1003, 18 Conn. App. 4, 1989 Conn. App. LEXIS 78 (Colo. Ct. App. 1989).

Opinion

Daly, J.

The plaintiffs appeal to this court from the judgment of the trial court dismissing their appeal from the decision of the named defendant, the Connecticut Indian Affairs Council (CIAC). The trial court dismissed the plaintiffs’ administrative appeal on the ground that they were not aggrieved and therefore lacked standing to pursue that appeal. We find error and hold that the plaintiffs have standing to appeal.

[6]*6Certain facts are relevant to the disposition of this appeal. The plaintiffs include (1) the Paucatuck Pequot Indians of Connecticut,1 (2) Helen LeGault, Ruth Geer and Raymond Geer, members of that tribe, and (3) Richard Williams, a tribal member and the tribal representative on the CIAC prior to the December 3, 1983 CIAC decision that is the subject of the plaintiffs’ administrative appeal. The defendants include (1) the CIAC,2 (2) Stilson Sands, chairman of the CIAC at the time of the decision, (3) the Eastern Pequot Indians of Connecticut,3 and (4) Royal Sebastian, William Sebastian and Lawrence Sebastian, tribal members of the Eastern Pequot. There are five Indian tribes recognized in Connecticut, namely, the Schaghticoke, the Pauca-tuck Pequot, the Mashantucket Pequot, the Mohegan and the Golden Hill Paugusset and each is entitled to one representative on the CIAC. General Statutes § 47-59a, 47-59b (a).

On December 7,1982, the individual defendants and the Eastern Pequot challenged Williams’ tribal representation on the CIAC, pursuant to the regulations of the department of environmental protection, §§ 47-59b-5 and 47-59b-6 of the Regulations of Connecticut State Agencies.4 Adjudicatory hearings were held and, on [7]*7December 3, 1983, the CIAC issued its decision. The CIAC found that, at the time of the challenge, there was no prevailing practice and usage concerning the determination of membership in the tribe, nor did the tribe have any practice or usage on file with the CIAC, as required by § 47-59b-5 of the regulations. The CIAC found it necessary to determine the eligibility and eligibility criteria for membership in the tribe, due to the absence of any tribal practice and usage for determining membership.5 The CIAC also declared the tribal [8]*8seat on the council vacant until such time as a new tribal government was declared and the necessary documents were submitted to the Cl AC.

The plaintiffs appealed this administrative decision to the Superior Court, pursuant to General Statutes § 4-183. The court conducted a hearing on aggrievement, at which Raymond Geer was the only witness. On the basis of its finding that none of the plaintiffs was aggrieved, the court dismissed their appeal. The question for our review is whether the tribal organization and the individual plaintiffs have been aggrieved by the CIAC decision, thereby conferring upon them standing to appeal that decision.

“ ‘ “The fundamental test for determining aggrievement encompasses a well-settled twofold determination: first, ‘the party claiming aggrievement must successfully demonstrate a specific personal and legal interest in the subject matter of the decision, as distinguished from a general interest, such as is the concern of all members of the community as a whole. Second, the party claiming aggrievement must successfully establish that this specific personal and legal interest has been specially and injuriously affected by the decision.’. . ’ Cannavo Enterprises, Inc. v. Burns, 194 Conn. 43, 47, 478 A.2d 601 (1984); Bakelaar v. West Haven, 193 Conn. 59, 65, 475 A.2d 283 (1984). ‘Aggrievement is established if “there is a possibility, as distinguished from a certainty, that some legally protected interest . . . has been adversely affected.” O’Leary v. McGuinness, 140 Conn. 80, 83, 98 A.2d 660 (1953).’ Hall v. Planning Commission, 181 Conn. 442, 445, 435 A.2d 975 (1980).” State Medical Society v. [9]*9Board of Examiners in Podiatry, 203 Conn. 295, 299-300, 524 A.2d 636 (1987).

The CIAC specifically ruled that it would “recognize as legitimate and eligible tribal members, any individual who presents adequate evidence that he [or] she is eligible within either the [s]tate statutes or the above criteria6 to be recognized as a member of the [Pauca-tuck Pequot] tribe.” The individual plaintiffs had already achieved tribal member status prior to the CIAC decision. As a result of the decision, they are required to reapply to the CIAC for a new determination of such status. The CIAC decision stripped the individual plaintiffs of their tribal member status. Thus, the individual plaintiffs have satisfied the test for determining aggrievement because they have shown that there is a possibility that a legally protected interest, namely, tribal member status, has been adversely affected by the CIAC’s decision.

The remaining issue is whether the trial court erred when it determined that the named plaintiff was not aggrieved. The United States Supreme Court has recognized two instances in which an organization has standing to sue. First, an organization has standing to sue in its own right if the associational ties of its members are injured. Warth v. Seldin, 422 U.S. 490, 510-11, 95 S. Ct. 2197, 45 L. Ed. 2d 343 (1975). Additionally, an organization has standing to sue on behalf of its injured members, even in the absence of injury to the organization itself. Id., 511; see Hunt v. Washington State Apple Advertising Commission, 432 U.S. 333, 343, 97 S. Ct. 2434, 53 L. Ed. 2d 383 (1977). An organization may assert both types of standing within the same action. Warth v. Seldin, supra, 511.

[10]*10In Connecticut Assn. of Health Care Facilities v. Worrell, 199 Conn. 609, 508 A.2d 743 (1986), our Supreme Court adopted the federal standard for representational7 standing as delineated by the United States Supreme Court in Hunt v. Washington State Apple Advertising Commission, supra. “ ‘[A]n association has standing to bring suit on behalf of its members when: (a) its members would otherwise have standing to sue in their own right; (b) the interests it seeks to protect are germane to the organization’s purpose; and (c) neither the claim asserted nor the relief requested requires the participation of individual members in the lawsuit.’Id., 343 . . . .” Connecticut Assn. of Health Care Facilities v. Worrell, supra, 616; see State Medical Society v. Board of Examiners in Podiatry, supra, 304.

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Bluebook (online)
555 A.2d 1003, 18 Conn. App. 4, 1989 Conn. App. LEXIS 78, Counsel Stack Legal Research, https://law.counselstack.com/opinion/paucatuck-eastern-pequot-indians-v-connecticut-indian-affairs-council-connappct-1989.