South Park Assoc., Ltd. v. Fair Rent Commn., No. Cvh 5651 (Jan. 6, 1998)

1998 Conn. Super. Ct. 750, 21 Conn. L. Rptr. 575
CourtConnecticut Superior Court
DecidedJanuary 6, 1998
DocketNo. CVH 5651
StatusUnpublished

This text of 1998 Conn. Super. Ct. 750 (South Park Assoc., Ltd. v. Fair Rent Commn., No. Cvh 5651 (Jan. 6, 1998)) is published on Counsel Stack Legal Research, covering Connecticut Superior Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
South Park Assoc., Ltd. v. Fair Rent Commn., No. Cvh 5651 (Jan. 6, 1998), 1998 Conn. Super. Ct. 750, 21 Conn. L. Rptr. 575 (Colo. Ct. App. 1998).

Opinion

[EDITOR'S NOTE: This case is unpublished as indicated by the issuing court.]MEMORANDUM OF DECISION This is an appeal by the plaintiff1 from two "orders" of the Fair Rent Commission ("Commission") of the Town of Manchester. In May, 1996, ten complaints were filed with the Commission by tenants at the South Park buildings. Although each complaint was different, the predominant theme of the complaints was that the plaintiff did not repair and maintain the premises in a workmanlike or timely manner. A lengthy hearing was held on July 22, 1996; two "orders" followed the hearing. The first, dated July 29, 1996, and sent by and signed by the town's director of health, listed "agreements" reached at the July 22 hearing; the second, dated August 7, 1996, and signed by the chairman of the commission, listed a number of additional "agreements" that had been reached at the hearing and stressed that Mr. Mrosek had thirty days from receipt of the order to complete the tasks. A motion at the conclusion of the July 22 hearing had been passed to the effect that if the items were not completed within 30 days, the monthly rent for each of the complainants would be reduced by the amount of fifty dollars per month of noncompliance. The plaintiff apparently corrected all or almost all of the actual code violations within the agreed upon period, but did not fix some of the other items, and appealed to CT Page 751 this court from both orders of the commission.

The appeal claims a variety of defects in the proceedings before the commission; in its amended complaint, the plaintiff alleges that notice of the hearing and of the July decision were defective; that the plaintiff was denied the opportunity to present evidence at the hearing; that the commission exceeded its statutory authority; that the August decision was issued without a hearing and an opportunity to be heard; and, more generally, that due process was violated. The answers of the defendants2 generally deny that there were any significant irregularities.3

I have read the lengthy transcript of the proceedings before the commission and the exhibits submitted to the commission4, and I find that there are several significant obstacles to traditional judicial review. First, and perhaps most significantly, the hearing was simply not conducted as an adjudicatory proceeding. Although witnesses were sworn, the proceedings were largely conversational and there was no clear adherence to any set of pleadings or other standard for relevance. Commissioners frequently "testified" about conditions and frequently made comments about what "George" ought to do to improve the conduct of his business. The hearing appeared to be more an opportunity for tenants to express their frustrations, and for all of those concerned to reach a mutually agreed upon plan, than an adjudication. Mr. Mrosek, though represented by counsel, also from the outset appeared interested in reaching an accommodation with the tenants. At the hearing, Mr. Mrosek typically agreed to address each problem raised by the tenants, and a timetable for repairs was agreed to. The sanction of a reduction of rent in the amount of fifty dollars per month per complainant was almost an afterthought and was not disputed at the hearing. At some point after the hearing the plaintiff apparently changed his mind, and this appeal followed.5

There are also difficulties with the record itself. Significant parts of the transcript are missing because words were inaudible to the transcriber; speakers frequently are not identified; and there are significant gaps when tapes ran out. At the conclusion of the hearing, for example, when the commissioners were presumably discussing the final order, the tape machine apparently was not running at all. As noted above, it was agreed that 42 exhibits were improperly included in the record, and a number of reports and correspondence generated after the hearing were included as exhibits. A number of items CT Page 752 which clearly were considered by the commissioners were never marked as exhibits and were not included in the record; most obviously, these include photographs of conditions.

I find, however, that the nature of the proceedings and of the order precludes judicial review. The actual motion adopted by the commission, Exhibit 114, stated that the owner shall, within thirty days, develop a plan for maintenance and handling tenant complaints, complete all items of maintenance and repair as agreed during the hearing, and provide janitorial service to certain areas twice monthly, and if these conditions are not met, the rent of all complainants will be reduced by $50.00 per month. Some further action of the commission would certainly seem to be required if the rent were to be reduced; that is, the order would not appear to be self-executing. Further, it appears from documents included, perhaps erroneously, in the record that work in fact was done in at least some of the units, and the commission indeed may find that there is no remaining controversy, or that any remaining controversy is considerably narrowed.6 Because some additional discretionary action on the part of the commission would be required before an order could be effective, and because effective judicial review is not possible in the present posture, the motion of the commission was not an appealable order.

"The considerations underlying the requirement of finality of an agency decision as a prerequisite to judicial review are akin to those involved in the ripeness doctrine as applied to administrative rulings. [I]ts basic rationale is to prevent the courts, through avoidance of premature adjudication, from entangling themselves in abstract disagreements over administrative policies, and also to protect the agencies from judicial interference until an administrative decision has been formalized and its effects felt in a concrete way by the challenging parties. Abbott Laboratories v. Gardner, 387 U.S. 136, 148-49, 87 S.Ct. 1507, 18 L.Ed.2d 681 (1967). The cases dealing with judicial review of administrative actions have interpreted the finality element in a pragmatic way. Id., 149. [T]he relevant considerations in determining finality are whether the process of administrative decision making has reached a stage where judicial review will not disrupt the orderly process of adjudication and whether rights or obligations have been determined or legal consequences will flow from the agency action. Port of Boston Marine Terminal Assn. v. Rederiaktiebolaget Transatlantic, 400 U.S. 62, 71, 91 S.Ct. 203, 27 L.Ed.2d 203 (1970)." (Internal quotation marks omitted.) CT Page 753 New Haven v. New Haven Police Union Local 530, 210 Conn. 597, 604, 557 A.2d 506 (1989). Another significant consideration is whether the agency intended its decision to be final.

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Bluebook (online)
1998 Conn. Super. Ct. 750, 21 Conn. L. Rptr. 575, Counsel Stack Legal Research, https://law.counselstack.com/opinion/south-park-assoc-ltd-v-fair-rent-commn-no-cvh-5651-jan-6-1998-connsuperct-1998.