Connecticut General Statutes

Conn. Gen. Stat. § 4-164 (2025)

Appeal from forfeiture

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(a) Any claimant aggrieved by an order of forfeiture of the Office of the Claims Commissioner made pursuant to subsection (a) of section 4-163 may appeal such order to the superior court for the judicial district in which he or she resides or, if he or she is not a resident of this state, to the superior court for the judicial district of New Britain.

(b) The action of the Office of the Claims Commissioner in approving or rejecting payment of any claim or part thereof shall be final and conclusive on all questions of law and fact and shall not be subject to review except by the General Assembly.

(1959, P.A. 685, S. 22; 1961, P.A. 476, S. 9; P.A. 75-605, S. 19, 27; P.A. 76-436, S. 250, 681; P.A. 78-280, S. 1, 2, 5, 127; P.A. 82-167, S. 6, 7; P.A. 88-230, S. 1, 12; P.A. 90-98, S. 1, 2; P.A. 93-142, S. 4, 7, 8; P.A. 95-220, S. 4–6; P.A. 99-215, S. 24, 29; P.A. 16-127, S. 21.)

History: 1961 act restated and clarified Subsec. (b); P.A. 75-605 replaced commission with claims commissioner; P.A. 76-436 replaced court of common pleas with superior court, effective July 1, 1978; P.A. 78-280 deleted the words “county or” in the phrase “county or judicial district” and replaced “Hartford county” with “the judicial district of Hartford-New Britain”; P.A. 82-167 amended Subsec. (b) to provide that only review is by the general assembly; P.A. 88-230 replaced “judicial district of Hartford-New Britain” with “judicial district of Hartford”, effective September 1, 1991; P.A. 90-98 changed the effective date of P.A. 88-230 from September 1, 1991, to September 1, 1993; P.A. 93-142 changed the effective date of P.A. 88-230 from September 1, 1993, to September 1, 1996, effective June 14, 1993; P.A. 95-220 changed the effective date of P.A. 88-230 from September 1, 1996, to September 1, 1998, effective July 1, 1995; P.A. 99-215 replaced “judicial district of Hartford” with “judicial district of New Britain” in Subsec. (a), effective June 29, 1999; P.A. 16-127 amended Subsec. (a) by making technical changes and amended Subsecs. (a) and (b) by substituting “Office of the Claims Commissioner” for “Claims Commissioner”, effective June 9, 2016.

Cited. 186 C. 300; 195 C. 534. P.A. 82-167, Sec. 6 of which amended this section, should be read as clarification of Superior Court's ongoing lack of jurisdiction to hear appeals from Claims Commissioner. 195 C. 534. Cited. 204 C. 259.

Cited. 44 CS 297.

Subsec. (b):

Not repealed by Ch. 54 or Sec. 4-189; does not bar appeal from decision of claims commission in violation of constitutional or statutory provisions, in excess of statutory authority or made upon unlawful procedure, and such appeals are governed by Ch. 54. 172 C. 603. Cited. 211 C. 199.

Notes of Decisions
Cited in 8 cases (2 in the last 5 years), 1977–2024 · leading case: Circle Lanes of Fairfield, Inc. v. Fay, 489 A.2d 363 (Conn. 1985).
Circle Lanes of Fairfield, Inc. v. Fay, 489 A.2d 363 (Conn. 1985). · cites it 4× “We were faced with a conflict between General Statutes § 4-164, which then made actions of the commission on claims “final and conclusive on all questions of law and fact and .”
Merly v. State, 558 A.2d 977 (Conn. 1989). · cites it 3× “*212 IV The plaintiff maintains that judicial review of the constitutionality of the special act is precluded by General Statutes § 4-164 (b), which provides that “[t]he action of the claims commissioner in approving or rejecting payment of any claim or part thereof shall be…”
State v. Magnano, 528 A.2d 760 (Conn. 1987). · cites it 2× “2d 71 (1977), which reconciled two conflicting statutes: General Statutes § 4-164, which prohibited an appeal from the decision of the claims commissioner; and General Statutes § 4-185 of the Uniform Administrative Procedure Act (UAPA), which provided for judicial review of all…”
Hirschfeld v. Comm'n on Claims, 376 A.2d 71 (Conn. 1977). · cites it 2× “” General Statutes § 4-164. In 1972, the Uniform Administrative Procedure Act, hereinafter the UAPA, took effect.”
Lynch v. State, 308 A.3d 1 (Conn. 2024). · cites it 2× “To the extent the state disputed the applicability of § 4-160 (b) because of alleged defects or shortcomings in the plaintiffs’ good faith certificate, it was incum bent on it to raise the issue with the Claims Commissioner while the matter was still under his review. In this…”
Reilly v. Smith, 855 A.2d 1000 (Conn. App. Ct. 2004). · cites it 2× “Accordingly, General Statutes § 4-164 (b) provides: “The action of the Claims Commissioner in approving or rejecting payment of any claim or part thereof shall be final and conclusive on all questions of law and fact and shall not be subject to review except by the General…”
William Raveis Real Est., Inc. v. Comm'r of Revenue Servs., 686 A.2d 140 (Conn. Super. Ct. 1995). · cites it 2× “82-167, § 6; General Statutes § 4-164. The court concluded that the statute should be read “as a clarification of the Superior Court’s ongoing lack of jurisdiction to hear appeals from the claims commissioner.”
Marland v. Univ. of Connecticut Health Ctr., 326 A.3d 1096 (Conn. 2024). “2d 858 (1996) (‘The legislature has established a system for the determination of claims against the state. . . . A significant part of that system is the appointment of a claims commissioner .”
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