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DuBaldo v. Department of Consumer Protection

Citations: 209 Conn. 719; 552 A.2d 813; 1989 Conn. LEXIS 16Docket: 13470

Court: Supreme Court of Connecticut; January 31, 1989; Connecticut; State Supreme Court

Narrative Opinion Summary

In this case, the principal of an electrical contracting company appealed the decision of the state electrical work examining board to suspend his contractor's license for 90 days. The suspension was based on a Department of Consumer Protection complaint regarding unsupervised apprentices. The Superior Court initially dismissed the appeal, but the appellant challenged this dismissal on several grounds, including the improper constitution of the board and due process violations. Specifically, the appellant argued that the board's journeyman members did not meet statutory requirements as they were not actively engaged in electrical contracting, contrary to General Statutes 20-331. The court agreed, finding that the board's composition was invalid, as the members were not involved in electrical work as required by statute. Consequently, the judgment was set aside, and the case was remanded for further proceedings, with the court emphasizing the need for a properly constituted board to exercise authority in license suspensions. This ruling underscores the importance of adhering to statutory mandates in administrative board compositions and the procedural fairness in disciplinary actions.

Legal Issues Addressed

Due Process in Disciplinary Proceedings

Application: DuBaldo argued that due process was violated due to the involvement of union officials in the board's decision-making process, impacting the fairness of the proceedings.

Reasoning: DuBaldo contested the dismissal on several grounds, including claims...due process violations involving union officials.

Engagement in Occupation Requirement

Application: The court determined that two journeyman members of the board were not engaged in the electrical occupation as defined by statute, thus invalidating the board's decision.

Reasoning: Both Carroll and Panagrossi identified as full-time union employees, but they were not 'engaged in [the] occupation' of electrical work as required by 20-331 and as defined in 20-330 (2).

Judicial Review of Administrative Decisions

Application: The Superior Court's dismissal of the appeal was overturned due to the improper composition of the board, necessitating further proceedings.

Reasoning: Consequently, the judgment is set aside, and the case is remanded for further proceedings consistent with this opinion.

Statutory Composition of Licensing Board

Application: The court found that the electrical work examining board was not properly constituted as required by statute, impacting its authority to suspend licenses.

Reasoning: The court found merit in this claim, noting that the terms of the statute require board members to be actively involved in the occupation, which was not the case for the two journeyman members.