Connecticut General Statutes

Conn. Gen. Stat. § 4-158 (2026)

Decision by Claims Commissioner, Deputy Claims Commissioner or special deputy. Request for legislative review. Payment of smaller claims. Annual report to General Assembly

✓ current as of May 2026

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(a) The Claims Commissioner, the Deputy Claims Commissioner or a special deputy may (1) order that a claim be denied or dismissed, (2) order immediate payment of a just claim in an amount not exceeding thirty-five thousand dollars, (3) recommend to the General Assembly payment of a just claim in an amount exceeding thirty-five thousand dollars, or (4) authorize a claimant to sue the state, as provided in section 4-160.

(b) Any person who has filed a claim in excess of fifty thousand dollars may request the General Assembly to review a decision of the Claims Commissioner, the Deputy Claims Commissioner or a special deputy (1) ordering the denial or dismissal of the claim pursuant to subdivision (1) of subsection (a) of this section, including denying or dismissing a claim that requests permission to sue the state, or (2) ordering immediate payment of a just claim in an amount not exceeding thirty-five thousand dollars pursuant to subdivision (2) of subsection (a) of this section. A person who has filed a claim that has been denied or dismissed by a special deputy pursuant to subsection (d) of section 4-160 may request the General Assembly to review such denial or dismissal. A request for review shall be in writing and (A) filed with the Office of the Claims Commissioner not later than twenty days after the date the person requesting such review receives a copy of the decision, and (B) include a summary, not to exceed two pages, of the factual and legal basis for requesting review by the General Assembly of the decision of the Claims Commissioner, the Deputy Claims Commissioner or a special deputy. The filing of a request for review shall automatically stay the decision of the Claims Commissioner, Deputy Claims Commissioner or special deputy.

(c) Pursuant to section 4-159, the Office of the Claims Commissioner shall submit to the General Assembly each claim for which a request for review has been filed under subsection (b) of this section, provided the request complies with the requirements set forth in said subsection (b).

(d) If the Claims Commissioner, the Deputy Claims Commissioner or a special deputy orders immediate payment of a just claim in an amount not exceeding thirty-five thousand dollars pursuant to subdivision (2) of subsection (a) of this section and a request for review is not timely filed pursuant to subsection (b) of this section, the Office of the Claims Commissioner shall deliver to the Comptroller a certified copy of the Claims Commissioner's, Deputy Claims Commissioner's or special deputy's order and the Comptroller shall make payment from such appropriation as the General Assembly may have made for the payment of claims or, in the case of contractual claims for goods or services furnished or for property leased, from the appropriation of the agency which received such goods or services or occupied such property.

(e) Whenever the Claims Commissioner deems it just and equitable, the Claims Commissioner may, at any time prior to the submission of a claim to the General Assembly pursuant to subsection (a) of section 4-159, vacate the decision made pursuant to subsection (a) of this section and undertake such further proceedings in accordance with this chapter as the Claims Commissioner may, in his or her discretion, deem appropriate.

(f) Not later than five days after the convening of each regular session, the Office of the Claims Commissioner shall report to the General Assembly on all claims decided pursuant to this section during the preceding calendar year. Such report shall include, but not be limited to, the following information for the preceding calendar year: (1) The total number of new claims filed; (2) the total number of claims disposed of; (3) the total number of claims that were dismissed; (4) the total number of claims that were denied; (5) a description of each order of immediate payment of a just claim in an amount not exceeding thirty-five thousand dollars, which description shall minimally include, the name of the claimant, the amount paid to the claimant and the reasoning for the payment to the claimant; and (6) the total number of claimants who were authorized to sue the state.

(1959, P.A. 685, S. 11; 1961, P.A. 476, S. 6; P.A. 75-605, S. 15, 27; P.A. 84-407, S. 1, 5; P.A. 05-170, S. 1; P.A. 09-44, S. 1; Sept. Sp. Sess. P.A. 09-7, S. 174; P.A. 13-225, S. 6; P.A. 16-127, S. 16; P.A. 19-182, S. 2; P.A. 21-91, S. 4; P.A. 22-79, S. 1; P.A. 23-131, S. 8; P.A. 24-44, S. 9.)

History: 1961 act specified payments in case of contractual claims for goods or services be made from agency's appropriation and added Subsec. (b); P.A. 75-605 replaced commission with claims commissioner and executive secretary with clerk of the office of the claims commissioner and raised limit for immediately payable claims and for those brought before the general assembly from $2,500 to $5,000; P.A. 84-407 amended section by increasing claim which commissioner may immediately approve from $5,000 to $7,500 and similarly amended corresponding provision re claims submitted to general assembly; P.A. 05-170 added Subsec. (a)(1) re authority to order that a claim be denied or dismissed, designating existing provision re authority to order immediate payment of a just claim in an amount not exceeding $7,500 as Subdiv. (2), added (a)(3) and (4) re authority to recommend payment of a just claim in an amount exceeding $7,500 and authority to authorize a claimant to sue the state, added new Subsec. (b) to authorize a person who has filed a claim for more than $7,500 to request the General Assembly to review a decision of the Claims Commissioner ordering the denial or dismissal of the claim or ordering immediate payment of the claim in an amount not exceeding $7,500, require the request be in writing and filed not later than 20 days after receipt of the decision and provide that the filing of the request automatically stays the decision, added new Subsec. (c) requiring the Claims Commissioner to submit each claim for which a request for review is filed to the General Assembly, designated existing provisions re delivery of a certified copy of the Claims Commissioner's order and payment by the Comptroller when the immediate payment of a claim in an amount not exceeding $7,500 is ordered as Subsec. (d) and amended said Subsec. to make provisions applicable if a request for review is not timely filed pursuant to Subsec. (b), designated existing provisions requiring the Claims Commissioner to report to the General Assembly on all claims decided pursuant to this section as Subsec. (e) and deleted former Subsec. (b) re procedure when a person wishes to protest an award and waive immediate payment; P.A. 09-44 added new Subsec. (e) authorizing Claims Commissioner to vacate a decision and undertake further proceedings deemed appropriate and redesignated existing Subsec. (e) as Subsec. (f), effective May 20, 2009, and applicable to claims filed prior to, on or after that date; Sept. Sp. Sess. P.A. 09-7 amended Subsec. (d) by deleting reference to clerk of the office, effective October 5, 2009; P.A. 13-225 amended Subsecs. (a), (b) and (d) to increase both the maximum amount for immediately payable just claims and the threshold amount for claims submitted to the General Assembly from $7,500 to $20,000, effective July 1, 2013; P.A. 16-127 amended Subsecs. (c) and (f) by substituting “Office of the Claims Commissioner” for “Claims Commissioner”, effective June 9, 2016; P.A. 19-182 amended Subsecs. (a), (b)(2) and (d) to increase both maximum amount for immediately payable just claims and threshold amount for recommended payment of claims which require review by the General Assembly from $20,000 to $35,000 and amended Subsec. (b) to increase threshold amount of a filed claim for which claimant may request review of decision of the Claims Commissioner by the General Assembly from $20,000 to $50,000, effective October 1, 2019, and applicable to any claim filed on or after October 1, 2019; P.A. 21-91 amended Subsec. (b) by adding provision re claims denied or dismissed by temporary deputy and adding reference to temporary deputy re staying decision, effective June 28, 2021; P.A. 22-79 amended Subsec. (f) by prescribing required content of report submitted to General Assembly; P.A. 23-131 amended Subsecs. (a) and (b) by adding references to “Deputy Claims Commissioner” and “temporary deputy” and further amended Subsec. (b) by removing requirement that a claim be for $50,000 or more in order for the claimant to seek review of the decision of the Claims Commissioner, Deputy Claims Commissioner or a temporary deputy, effective July 1, 2023; P.A. 24-44 amended Subsecs. (a) and (b) by substituting “special deputy” for “temporary deputy” and further amended Subsec. (b) by adding requirement that claim be in excess of $50,000 in order for claimant to seek General Assembly review of decision and requiring claimant seeking review by General Assembly to provide a written summary of the factual and legal basis for requesting review of decision, amended Subsec. (c) by adding request for review shall be submitted to General Assembly provided request complies with Subsec. (b) and amended Subsec. (d) by adding references to Deputy Claims Commissioner and special deputy, effective July 1, 2024.

Cited. 186 C. 300; 204 C. 17; 209 C. 679; 211 C. 199; 222 C. 280.

Subsec. (e):

Subsec. unambiguously confers broad discretion to commissioner to vacate prior decision if the decision being vacated was made pursuant to Subsec. (a), the decision has not been submitted to the General Assembly pursuant to Sec. 4-159(a), and vacating the decision would be “just and equitable”; commissioner has discretion to vacate the three types of decisions to which Subsec. (a) applies whenever he deems it just and equitable for the limited period of time prior to submission of the claim to the General Assembly, but with respect to all other decisions that commissioner has made pursuant to Subsec. (a), he retains discretion to vacate those decisions at any time in the future; plain language of Subsec. does not reference request for review process, and there is no express textual basis for limiting the provision's application to cases in which a request for review has been filed or to impute a request for review requirement. 305 C. 654.

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Notes of Decisions

Cited in 31 cases (5 in the last 5 years), 1974–2026 · leading case: Chotkowski v. State, 690 A.2d 368 (Conn. 1997).

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Chotkowski v. State, 690 A.2d 368 (Conn. 1997). · cites it 8× “Because of this argument, the commissioner, instead of adjudicating the claim himself pursuant to General Statutes § 4-158 or making a recommendation to the legislature of an amount for payment pursuant to General Statutes § 4-159, authorized the plaintiff to institute this…”

Martinez v. Dep't of Pub. Saf., 818 A.2d 758 (Conn. 2003). · cites it 6× “General Statutes § 4-158 (a). 8 If the claim exceeds $7500, the claims commissioner must make a recommendation to the General Assembly suggesting payment or rejection, and the General Assembly may accept, reject or alter the claims commissioner’s recommendation.”

St. George v. Gordon, 825 A.2d 90 (Conn. 2003). · cites it 6× “See General Statutes § 4-158. 5 Indeed, because the right to indemnification under § 5-141d is predicated on certain factual findings—that the employee was acting in the discharge of his duties or within the scope of his employment and that the act was not wanton, reckless or…”

Rivers v. City of New Britain, 950 A.2d 1247 (Conn. 2008). · cites it 4× “Pursuant to General Statutes § 4-158 (a), the claims commissioner “may (1) order that a claim be denied or dismissed, (2) order immediate payment of a just claim in an amount not exceeding seven thousand five hundred dollars, (3) recommend to the General Assembly payment of a…”

D'ERAMO v. Smith, 872 A.2d 408 (Conn. 2005). · cites it 4× “With respect to such claims, the claims commissioner had the authority to hold trial-like hearings; see General Statutes § 4-151; to make findings of fact and issue appropriate orders; see General Statutes § 4-154; to approve immediate payment of just claims not exceeding $7500;…”

184 Windsor Avenue, LLC. v. State, 875 A.2d 498 (Conn. 2005). · cites it 6× “” Pursuant to General Statutes § 4-158 (a), 7 the claims commissioner may approve immediate payment of just claims not exceeding $7500.”

Miller v. Egan, 828 A.2d 549 (Conn. 2003). · cites it 2× “The com *320 missioner has jurisdiction, pursuant to General Statutes § 4-158 (a), to “approve immediate payment of just claims not exceeding seven thousand five hundred dollars.”

Envirotest Sys. Corp. v. Comm'r of Motor Vehs., 978 A.2d 49 (Conn. 2009). · cites it 4× “General Statutes § 4-158 (a). If the claim exceeds $7500, the claims commissioner must make a recommendation to the General Assembly suggesting payment or rejection, and the General Assembly may accept, reject or alter the claims commissioner’s recommendation.”

Sullivan v. State, 457 A.2d 304 (Conn. 1983). · cites it 4× “7 After a hearing, the commis- *556 missioner may approve immediately any claim not exceeding $5000 which he determines is a “just claim”; General Statutes §4-158; one “which in equity and justice the state should pay, provided the state has caused damage or injury or has…”

Martinez v. Dep't of Pub. Saf., 784 A.2d 347 (Conn. 2001). · cites it 4× “Pursuant to General Statutes § 4-158, the claims commissioner has sole discretion to pay or reject any claim under $7500.”

Merly v. State, 558 A.2d 977 (Conn. 1989). · cites it 4× “Pursuant to General Statutes § 4-158 (a), the claims commissioner reported to the General Assembly at its February 1984 session his action denying the plaintiff’s claim and sought approval thereof.”

State v. Avoletta, 212 Conn. App. 309 (Conn. App. Ct. 2022). · cites it 18× “By contrast, General Statutes § 4-158 (b)13 or General Statutes § 4-159 (b)14 authorize the legisla- ture to review, vacate, and remand decisions of the commissioner over claims that were timely filed.”

Show all 31 citing cases →

— Conn. Gen. Stat. § 4-158(a) — 2 cases

Rivers v. City of New Britain, 950 A.2d 1247 (Conn. 2008). “Pursuant to General Statutes § 4-158 (a), the claims commissioner “may (1) order that a claim be denied or dismissed, (2) order immediate payment of a just claim in an amount not exceeding seven thousand five hundred dollars, (3) recommend to the General Assembly payment of a…”

Envirotest Sys. Corp. v. Comm'r of Motor Vehs., 978 A.2d 49 (Conn. 2009). “General Statutes § 4-158 (a). If the claim exceeds $7500, the claims commissioner must make a recommendation to the General Assembly suggesting payment or rejection, and the General Assembly may accept, reject or alter the claims commissioner’s recommendation.”

— Conn. Gen. Stat. § 4-158(b) — 1 case

Perez v. Univ. of Connecticut, 189 A.3d 664 (Conn. App. Ct. 2018).

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