State of Connecticut, Judicial Branch v. Commission on Human Rights & Opportunities, Office of Public Hearings

── State of Connecticut, Judicial Branch v. Commission on Human Rights & Opportunities, Office of Public Hearings ── Court: Supreme Court of Connecticut Date: April 14, 2026 Author: McDonald Category: General ************************************************ The “officially released” date that appears near the beginning of an opinion is the date the opinion will be published in the Connecticut Law Journal or the date it is released as a slip opinion. The operative date for the beginning of all time periods for the filing of postopinion motions and petitions for certification is the “officially released” date appearing in the opinion. All opinions are subject to modification and technical correction prior to official publication in the Connecti- cut Law Journal and subsequently in the Connecticut Reports or Connecticut Appellate Reports. In the event of discrepancies between the advance release version of an opinion and the version appearing in the Connecticut Law Journal and subsequently in the Connecticut Reports or Connecticut Appellate Reports, the latest version is to be considered authoritative. The syllabus and procedural history accompanying an opinion that appear in the Connecticut Law Journal and subsequently in the Connecticut Reports or Connecticut Appellate Reports are copyrighted by the Secretary of the State, State of Connecticut, and may not be reproduced or distributed without the express written permission of the Commission on Official Legal Publications, Judicial Branch, State of Connecticut. ************************************************  State of Connecticut, Judicial Branch v. Commission on Human Rights & Opportunities, Office of Public Hearings STATE OF CONNECTICUT, JUDICIAL BRANCH v. COMMISSION ON HUMAN RIGHTS AND OPPORTUNITIES, OFFICE OF PUBLIC HEARINGS, ET AL. (SC 21148) McDonald, D’Auria, Ecker, Dannehy and Suarez, Js. Syllabus The complainant, M, an attorney who sought reinstatement to the Connecticut bar, filed a complaint with the defendant administrative agency, the Com- mission on Human Rights and Opportunities, alleging that the plaintiff, the Connecticut Judicial Branch, which administers the attorney discipline and licensing process, had discriminated or retaliated against her in the proceedings involving her reinstatement. The commission’s human rights referee denied the plaintiff’s motion to dismiss M’s complaint, and, pursuant to statute (§§ 4-183 and 46a-94a (a)), the plaintiff filed in the trial court an interlocutory administrative appeal from that ruling, asserting, inter alia, that the separation of powers doctrine afforded the plaintiff immunity from suit. The trial court rendered judgment sustaining the plaintiff’s adminis- trative appeal and remanded the case to the commission with direction to dismiss M’s complaint, reasoning that the commission’s assertion of jurisdic- tion over the plaintiff’s decisions regarding M’s reinstatement violated the separation of powers doctrine because it was within the exclusive authority of the Judicial Branch to regulate attorneys and to admit attorneys to the practice of law. Thereafter, the commission appealed from the trial court’s judgment sustaining the plaintiff’s administrative appeal, claiming that the trial court lacked subject matter jurisdiction over the plaintiff’s interlocu- tory administrative appeal and that the court incorrectly concluded that the separation of powers doctrine barred the commission from exercising jurisdiction over M’s complaint. Held: The trial court had subject matter jurisdiction over the plaintiff’s interlocu- tory administrative appeal under §§ 4-183 (b) and 46a-94a (a). Section 4-183 (b) permits an interlocutory appeal from an agency ruling only if, among other things, postponement of the appeal would result in an inadequate remedy, and this court has previously held that, under § 4-183 (b), a colorable claim to a right of immunity from suit is protected from the immediate and irrevocable loss that would be occasioned by having to defend an action through the availability of an interlocutory appe