Connecticut General Statutes

Conn. Gen. Stat. § 10-145 (2026)

Certificate necessary to employment. Forfeiture for noncompliance. Substitute teachers

✓ current as of May 2026

Find cases: SyfertCases citing this section CT-CGAcga.ct.gov (official) JustiaTitle on Justia CornellLII Search CasesGoogle Scholar

(a) No teacher, supervisor, administrator, special service staff member or school superintendent, except as provided for in section 10-157, shall be employed in any of the schools of any local or regional board of education unless such person possesses an appropriate state certificate, nor shall any such person be entitled to any salary unless such person can produce such certificate dated prior to or on the first day of employment, except as provided for in section 10-157; provided nothing in this subsection shall be construed to prevent the board of education from prescribing qualifications additional to those prescribed by the regulations of the State Board of Education and provided nothing in this subsection shall be construed to prevent any local or regional board of education from contracting with a licensed drivers' school approved by the Commissioner of Motor Vehicles for the behind-the-wheel instruction of a driver instruction course, to be given by driving instructors licensed by the Department of Motor Vehicles. No person shall be employed in any of the schools of any local or regional board of education as a substitute teacher unless such person (1) holds a bachelor's degree, provided the Commissioner of Education may waive such requirement for good cause upon the request of a superintendent of schools, and (2) is on a list maintained by the local or regional board of education pursuant to subsection (f) of section 10-222c. A local or regional board of education may employ a person as a substitute teacher in the same assignment without a substitute authorization issued by the Department of Education for a period not to exceed sixty school days.

(b) If the State Board of Education determines that a local or regional board of education is not in compliance with any provision of sections 10-144o to 10-149, inclusive, and section 10-220a, the State Board of Education may require the local or regional board of education to forfeit of the total sum which is paid to such board of education from the State Treasury an amount to be determined by the State Board of Education, which amount shall be not less than one thousand dollars nor more than ten thousand dollars. The amount so forfeited shall be withheld from a grant payment, as determined by the commissioner, during the fiscal year following the fiscal year in which noncompliance is determined pursuant to this subsection. Notwithstanding the penalty provision of this section, the State Board of Education may waive such forfeiture if the board determines that the failure of the local or regional board of education to comply with such a provision was due to circumstances beyond its control.

(1949 Rev., S. 1432; 1961, P.A. 517, S. 116; 1971, P.A. 456, S. 5; P.A. 78-218, S. 93; May Sp. Sess. P.A. 86-1, S. 21, 58; P.A. 87-499, S. 5, 34; P.A. 89-137, S. 1, 14; P.A. 93-353, S. 49, 52; P.A. 07-241, S. 5; June 19 Sp. Sess. P.A. 09-1, S. 15; Sept. Sp. Sess. P.A. 09-6, S. 48; P.A. 11-27, S. 1; P.A. 15-215, S. 16; P.A. 16-67, S. 4; P.A. 23-159, S. 18.)

History: 1961 act added regional district; 1971 act added proviso for contracts with licensed drivers' schools; P.A. 78-218 deleted reference to “supervising agents”, substituted “local or regional board of education” for “town or regional district” and made technical changes; May Sp. Sess. P.A. 86-1 required administrators to have state certificates, substituted “employment” for “the opening of school” re dating of certificates and deleted provision that certificates in force July 1, 1935, are valid and renewable; P.A. 87-499 deleted principal and added special service staff member to list of persons to whom the section applies and added that the certificate may be dated the first day of employment; P.A. 89-137 added Subsec. (a) designation and new Subsec. (b) re forfeiture of funds by local and regional boards of education for noncompliance with certain statutes; P.A. 93-353 amended Subsec. (a) to add the requirement that a substitute teacher hold a bachelor's degree unless such requirement is waived, effective July 1, 1993; (Revisor's note: In 1997 references throughout the general statutes to “Motor Vehicle(s) Commissioner” and “Motor Vehicle(s) Department” were replaced editorially by the Revisors with “Commissioner of Motor Vehicles” or “Department of Motor Vehicles”, as the case may be, for consistency with customary statutory usage); P.A. 07-241 amended Subsec. (a) to add language re exception provided for in Sec. 10-157, effective July 1, 2007; June 19 Sp. Sess. P.A. 09-1 amended Subsec. (a) by deleting provision re waiver of requirement that substitute teachers hold a bachelor's degree, effective July 1, 2009; Sept. Sp. Sess. P.A. 09-6 amended Subsec. (a) to add exception to bachelor's degree requirement for substitute teachers applicable to school year commencing July 1, 2009, effective October 5, 2009; P.A. 11-27 amended Subsec. (a) by deleting exception to bachelor's degree requirement for substitute teachers applicable to school year commencing July 1, 2009, adding provision re waiver of requirement that substitute teachers hold a bachelor's degree and making technical changes, effective July 1, 2011; P.A. 15-215 made a technical change in Subsec. (a), effective July 1, 2015; P.A. 16-67 amended Subsec. (a) by designating existing provision re substitute teachers to hold bachelor's degree as Subdiv. (1) and by adding Subdiv. (2) re list maintained by local or regional board of education, effective July 1, 2016; P.A. 23-159 amended Subsec. (a) by adding provision re board may employ substitute teacher in same assignment without a substitute authorization for period not to exceed 60 school days, effective July 1, 2023.

Cited. 96 C. 720. Certificate to teach or as superintendent is not “appropriate” certificate for principal or vice principal; certificate issued under old law continues valid even for new employee so far as it is appropriate for position; “new” teacher includes one formerly employed who has definitely severed connection with the schools. 123 C. 515. Cited. 138 C. 280; 152 C. 151. Teacher employed without an appropriate state certificate is illegally employed and cannot obtain tenure during this period. 167 C. 444. Cited. 177 C. 68; 200 C. 21; 210 C. 286; 221 C. 549; 240 C. 119.

Cited. 5 CA 253; 32 CA 6.

Prevention of the issuance of a certificate by malicious or false representations is a legal wrong. 14 CS 28.

(Return to Chapter
Table of Contents)

(Return to
List of Chapters)

(Return to
List of Titles)

Notes of Decisions

Cited in 10 cases, 1964–2016 · leading case: Connecticut Educ. Ass'n v. Tirozzi, 554 A.2d 1065 (Conn. 1989).

Sort: Relevance Newest Treatment

Connecticut Educ. Ass'n v. Tirozzi, 554 A.2d 1065 (Conn. 1989). · cites it 5× “to 1989) § 10-145, 3 enjoins local boards of education from employing or paying any teacher who does not hold an appropriate state-issued teaching certificate.”

Kelley v. Bonney, 606 A.2d 693 (Conn. 1992). · cites it 2× “” General Statutes § 10-145 provides in relevant part: “(a) No teacher, supervisor, administrator, special service staff member or school superintendent shall be employed in any of the schools of any local or regional board of education unless such person possesses an…”

Meyers v. Kishimoto, 217 F. Supp. 3d 563 (D. Conn. 2016). · cites it 5× “Further underscoring this requirement, Conn. Gen. Stat. § 10-145 generally prohibits the employment of, and the payment of a salary to, any teacher who does not possess a valid teaching certificate.”

Connecticut State Bd. of Labor Relations v. Bd. of Educ., 411 A.2d 28 (Conn. 1979). · cites it 3× “The short answer to the board’s claim that teaehers employed in the summer school program are not required by statute to be certified is that all *73 teachers are required to he certified by § 10-145 (the teacher certification statute).”

Drahan v. Bd. of Educ., 680 A.2d 316 (Conn. App. Ct. 1996). · cites it 2× “” General Statutes § 10-144o (9), which is applicable only to General Statutes §§ 10-145 to 10-158a, inclusive, provides that “ ‘[o]ne year’ means one school year.”

Ames v. Bd. of Educ., 356 A.2d 100 (Conn. 1975). · cites it 4× “The defendant board’s attempt to terminate for canse the plaintiff’s employment was not related to the question of his certificate. The plaintiff makes the claim that he did not lose his tenure status owing to his lack of certification for the period of July 1,1968, to June…”

Connecticut Educ. Ass'n v. State Bd. of Labor Relations, 498 A.2d 102 (Conn. App. Ct. 1985). “The appropriate deference which should be accorded by our state courts to decisions of the labor board was set forth in an earlier case arising under the Teacher Negotiation Act in which the labor board was required to construe that act in light of the Connecticut Teacher…”

McKee v. Bd. of Educ., 84 Educ. L. Rep. 346 (Conn. App. Ct. 1993). · cites it 2× “The board’s reasoning for this contention is that the job description for high school special education counselor, requiring standard certification and certification in special education, has increased the qualifications necessary for the position pursuant to General Statutes §…”

Herzig v. Bd. of Educ., 204 A.2d 827 (Conn. 1964). “Extensive supervisory control over the local board is con *151 ferred, on the state board of education; §10-4; courses of instruction and rules for furnishing them, are explicitly defined; §§ 10-15 — 10-24; the qualifications of teachers who may be employed by the local board…”

Loftus v. Bd. of Educ., 509 A.2d 500 (Conn. 1986). · cites it 9× “General Statutes § 10-145 provides that “[n]o teacher .”

Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.