Town of Haddam v. Lapointe

680 A.2d 1010, 42 Conn. App. 631, 1996 Conn. App. LEXIS 440
CourtConnecticut Appellate Court
DecidedAugust 20, 1996
Docket14637
StatusPublished
Cited by21 cases

This text of 680 A.2d 1010 (Town of Haddam v. Lapointe) 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
Town of Haddam v. Lapointe, 680 A.2d 1010, 42 Conn. App. 631, 1996 Conn. App. LEXIS 440 (Colo. Ct. App. 1996).

Opinion

SPEAR, J.

The plaintiffs1 sought injunctive and other relief claiming that the defendant converted a summer cottage to a year-round residence without meeting the requirements of the public health code. Regs., Conn. State Agencies § 19-13-B100.2 The trial court rendered judgment for the defendant and the plaintiffs appeal, asserting that the trial court improperly (1) required the plaintiffs to prove that the defendant’s septic system violated the public health code even though the defendant failed to heed the plaintiffs’ notice of the health code violation and failed to exhaust her administrative remedies with respect to that notice, (2) found that § 19-13-B100 of the Regulations of Connecticut State Agencies was unconstitutionally vague, and (3) found that “the [plaintiff town] is using the health code to enforce its determination that it wishes to limit winterization of seasonal homes without promulgating regulations and standards.” We agree with the plaintiffs’ first claim and reverse the judgment of the trial court.3

The record discloses the following relevant facts and procedural history. The defendant is the fee owner of property located at 78 West Shore Drive in the town of Haddam. She purchased the property on December 18, 1990, by warranty deed. On March 24,1992, the plaintiff [633]*633director of health sent the defendant a notice of violation4 stating that she was in violation of § 19-13-B100 of the public health code.5 The notice clearly stated that a person aggrieved by the director of health may appeal the order by telephoning the office of the commissioner of health services (now the commissioner of public health and addiction services) within forty-eight hours, but the telephone call must be followed by a letter of appeal within seven days pursuant to § 19-2a-34 of the Regulations of Connecticut State Agencies.6 The defendant indicated her intent to appeal the order by [634]*634telephoning the commissioner within the forty-eight hour period, but failed to file a letter of appeal within seven days. Consequently, her administrative appeal was dismissed on April 14, 1992.

The plaintiffs thereafter commenced an action in Superior Court seeking, inter alia, temporary and permanent injunctive relief requiring the defendant to cease and desist from using the subsurface sewage disposal system on a year-round basis. After conducting an evidentiary hearing, the trial court denied the plaintiffs’ request for a permanent injunction. This appeal followed.

The plaintiffs first contend that the trial court improperly required the plaintiffs to prove a violation of the public health code even though the defendant had failed to exhaust her administrative remedies. We agree.

A director of health has the authority to examine and cause to be abated nuisances and sources of filth injurious to the public health pursuant to General Statutes § 19a-206.7 If a party chooses to challenge an order [635]*635issued by the director of health, the party must appeal to the commissioner of public health and addiction services pursuant to § 19a-2a-34 of the state regulations.8 A party aggrieved by the agency’s decision may then appeal to the Superior Court. The judicial review of an administrative agency’s actions is governed by General Statutes § 4-183,8 the Uniform Administrative [636]*636Procedures Act. Where a party appeals an agency’s decision, a reviewing court may grant relief only where the decision is “arbitrary, illegal or not reasonably supported by the evidence.” (Internal quotation marks omitted.) Red Hill Coalition, Inc. v. Conservation Commission, 212 Conn. 710, 718, 563 A.2d 1339 (1989). A showing that another decision maker might have reached a different conclusion is not sufficient to satisfy this burden. Newtown v. Keeney, 234 Conn. 312, 319, 661 A.2d 589 (1995). If an order to remove or abate is not complied with, § 19a-206 (b) provides that the director of health “may institute and maintain a civil action for injunctive relief in any court of competent jurisdiction . . . and such court shall have the power to grant such relief upon notice and hearing . . . .”

It is well established that a party must exhaust all administrative remedies before that party may ask a court to rule on the very issues that the administrative process was meant to test. Pet v. Dept. of Health Services, 207 Conn. 346, 351-52, 542 A.2d 672 (1988); see also Greater Bridgeport Transit Districts. Local Union 1336, 211 Conn. 436, 438, 559 A.2d 1113 (1989). The exhaustion doctrine “reflects the legislative intent that such issues be handled in the first instance by local administrative officials in order to provide aggrieved persons with full and adequate administrative relief, and to give the reviewing court the benefit of the local board’s judgment.” Greenwich v. Kristoff 180 Conn. 575, 578, 430 A.2d 1294 (1980). It also “relieves courts of the burden of prematurely deciding questions that, entrusted to an agency, may receive a satisfactory administrative disposition and avoid the need for judicial review.” Owner-Operators Independent Drivers Assn. of America v. State, 209 Conn. 679, 692, 553 A.2d 1104 (1989). “ ‘[Fjrequent and deliberate flouting of [637]*637administrative processes could weaken the effectiveness of an agency by encouraging people to ignore its procedures.’ ” Cannata v. Dept. of Environmental Protection, 215 Conn. 616, 625, 577 A.2d 1017 (1990), quoting McKart v. United States, 395 U.S. 185, 194-95, 89 S. Ct. 1657, 23 L. Ed. 2d 194 (1969).

It would violate the exhaustion doctrine and its policy underpinnings to allow a defendant who has failed to exhaust administrative remedies to defeat an agency’s injunction action on issues that could have been contested in the administrative process. We conclude that the plaintiffs were not required to prove a violation of the public health code.

Proof of a regulatory violation is not required if “the defendant has chosen not to attack the reasonableness of the order . . . [and] factfinding has been entrusted by the legislature to the administrative agency and an injunction is sought to enforce an administrative order in furtherance of a vital public interest.” Carothers v. Connecticut Building Wrecking Co., 19 Conn. App. 216, 222, 561 A.2d 971 (1989), citing Water Resources Commission v. Connecticut Sand & Stone Corp., 170 Conn.

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Bluebook (online)
680 A.2d 1010, 42 Conn. App. 631, 1996 Conn. App. LEXIS 440, Counsel Stack Legal Research, https://law.counselstack.com/opinion/town-of-haddam-v-lapointe-connappct-1996.