Stepney, LLC v. Town of Fairfield
263 Conn. 558, 2003 Conn. LEXIS 194, 821 A.2d 725 (2003)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
A party must exhaust all available and adequate administrative remedies before seeking judicial review in a court, even when challenging the facial validity or constitutionality of a regulation, unless it can be demonstrated that pursuing such remedies would be futile.
Facts:
- Stepney, LLC, a limited liability corporation, owned and rented out two single-family homes in the town of Fairfield.
- For many years, Stepney annually obtained a certificate of rental occupancy from Fairfield in compliance with the town's health code.
- In 1999, Fairfield amended its health code regulation (regulation 3.3) and the associated application form.
- The amended application required landlords to provide tenants' license plate numbers and to obtain tenants' signatures certifying they would comply with applicable laws and occupancy limits.
- Despite its properties being rented in 1999, Stepney failed to apply for the certificates under the amended regulation.
- After Stepney filed a lawsuit, Arthur Leffert, Fairfield's Director of Health, issued an order of compliance, directing Stepney to apply for a certificate pursuant to the amended regulation.
Procedural Posture:
- Stepney, LLC sued the town of Fairfield in the trial court (Superior Court), seeking declaratory and injunctive relief against the enforcement of a health code ordinance.
- Stepney filed an administrative appeal of a compliance order with the state board of health but subsequently withdrew the appeal.
- At trial, Fairfield moved to dismiss the action for lack of subject matter jurisdiction, arguing Stepney failed to exhaust its administrative remedies.
- The trial court denied Fairfield's motion to dismiss.
- The trial court rendered judgment in favor of Stepney, finding the ordinance void.
- Fairfield (appellant) appealed the trial court's judgment to the Appellate Court, and the case was transferred to the Supreme Court of Connecticut.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does a trial court have subject matter jurisdiction over a plaintiff's challenge to the validity of a municipal health ordinance when the plaintiff has failed to exhaust an available statutory administrative appeal process?
Opinions:
Majority - Katz, J.
No. A trial court lacks subject matter jurisdiction over a challenge to a municipal ordinance when the plaintiff has failed to exhaust adequate administrative remedies. The doctrine of exhaustion of administrative remedies requires a party to pursue the full administrative process before seeking judicial relief. In this case, a statutory appeal process was available to the plaintiff through the Commissioner of Public Health. The court reasoned that the Commissioner had the authority and expertise to determine whether the town's regulation was inconsistent with state law and could have provided adequate relief by vacating the compliance order. The court rejected the argument that an exception applied, noting that the futility and constitutional challenge exceptions are construed narrowly. Simply alleging a constitutional violation does not excuse the exhaustion requirement when an administrative procedure could have resolved the dispute on other grounds.
Analysis:
This decision strongly reaffirms the doctrine of exhaustion of administrative remedies, making it more difficult for litigants to bypass administrative agency proceedings. It clarifies that even facial challenges to a regulation's validity or constitutionality are generally insufficient to waive the exhaustion requirement. The ruling prioritizes agency expertise and autonomy, ensuring that courts do not prematurely intervene in matters delegated to administrative bodies by the legislature. This precedent forces parties to fully engage with the administrative process, potentially resolving disputes without court involvement and ensuring that if a case does reach a court, it is accompanied by a well-developed factual record from the agency.
