Stepney, LLC v. Town of Fairfield

Summary

The Connecticut Supreme Court held that the trial court lacked subject-matter jurisdiction because Stepney, LLC failed to exhaust its administrative remedies under General Statutes § 19a-229. The court concluded that the Commissioner of Public Health could have reviewed the validity of Fairfield’s rental-occupancy regulation and provided adequate relief, so the constitutional and ultra vires challenges did not excuse exhaustion. The judgment for Stepney was reversed, and the case was remanded with direction to dismiss.

Holdings

1. Because an adequate statutory administrative remedy existed under General Statutes § 19a-229, Stepney was required to exhaust that remedy before seeking judicial relief, and its failure to do so deprived the Superior Court of subject matter jurisdiction.
2. A challenge asserting that a municipal health regulation exceeded statutory authority does not excuse exhaustion when the administrative agency can grant adequate relief and address the issue within its delegated authority.
3. The mere assertion of constitutional claims does not excuse exhaustion of an otherwise adequate administrative remedy; judicial bypass is limited to circumstances in which pursuing the administrative remedy would be demonstrably futile because the agency lacks authority to provide adequate relief.

Questions Presented

1. Whether Stepney's failure to exhaust its administrative appeal under General Statutes § 19a-229 deprived the Superior Court of subject matter jurisdiction.
2. Whether the facial validity, ultra vires, and constitutional challenges to Fairfield's regulation 3.3 excused exhaustion because administrative relief allegedly would have been futile.
3. Whether Fairfield's regulation exceeded the authority granted to municipal health authorities under General Statutes § 19a-207.

Disposition

reversed_and_remanded