Conn. Gen. Stat. » Title 04 — MANAGEMENT OF STATE AGENCIES · Chapter 54 — Uniform Administrative Procedure Act
Connecticut General Statutes

Conn. Gen. Stat. § 4-176e (2026)

Agency hearings

✓ current as of May 2026
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Except as otherwise required by the general statutes, a hearing in an agency proceeding may be held before (1) one or more hearing officers, provided no individual who has personally carried out the function of an investigator in a contested case may serve as a hearing officer in that case, or (2) one or more of the members of the agency.

(P.A. 88-317, S. 11, 107.)

History: P.A. 88-317 effective July 1, 1989, and applicable to all agency proceedings commencing on or after that date.

Cited. 217 C. 130; 226 C. 105; 239 C. 32.

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Notes of Decisions
Cited in 16 cases (1 in the last 5 years), 1991–2024 · leading case: New England Rehab. Hosp. of Hartford, Inc. v. Comm'n on Hospitals & Health Care, 627 A.2d 1257 (Conn. 1993).
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New England Rehab. Hosp. of Hartford, Inc. v. Comm'n on Hospitals & Health Care, 627 A.2d 1257 (Conn. 1993). · cites it 13× “properly (1) conducted an investigatory hearing after the plaintiffs had filed their application for a certificate of need, (2) introduced a report containing the findings and conclusions from this hearing into evidence at the subsequent contested hearing, and (3) permitted…”
Tele Tech of Connecticut Corp. v. Dep't of Pub. Util. Control, 855 A.2d 174 (Conn. 2004). · cites it 8× “With this principle in mind, we conclude that the statutory scheme strongly suggests that the term “proceedings,” and the terms “hearing” and “final decision,” as used in other related statutory provisions in UAPA, namely, General Statutes §§ 4-176e 18 and 4-179 (a), 19 *798…”
Comm'n on Human Rights & Opportunities v. Bd. of Educ., 855 A.2d 212 (Conn. 2004). · cites it 4× “If the agent finds reasonable cause, the state board, which also has subpoena power, then conducts an inquiry, at which the local board has the power to be heard, under General Statutes §§ 4-176e through 4-184 of the UAPA.”
Town of Stratford v. State Bd. of Mediation & Arbitration, 153 L.R.R.M. (BNA) 2990 (Conn. 1996). · cites it 7× “Second, § 4-186 (c) does not exempt the board of mediation and arbitration from all the provisions of the UAPA; it exempts the board only from the provisions of General Statutes § 4-176e and General Statutes §§ 4-177 through 4-183.”
Gonzalez v. State Elections Enf't Comm'n, 77 A.3d 790 (Conn. App. Ct. 2013). · cites it 5× “Her due process claim arises from her contention that Cashman violated General Statutes § 4-176e, 4 which prevents the same person who investigated a contested matter to be the hearing officer in a contested hearing on the same matter, when he voted to find that there was reason…”
Gerardi v. City of Bridgeport, 985 A.2d 328 (Conn. 2010). · cites it 2× “This subsection of the statute, which is the only portion that addresses violations of the statute, authorizes the state labor commissioner to levy civil penalties for violations of the statute after a hearing conducted in accordance with General Statutes §§ 4-176e to 4-184.…”
Vernon Vill., Inc. v. Carothers, 585 A.2d 76 (Conn. 1991). · cites it 2× “…a license.” Regs., Conn. State Agencies § 22a-3a-l (a) (1) (A). See Public Acts 1988, No. 88-317, § 11 (codified as General Statutes § 4-176e) (referring to “a hearing in an agency proceeding”), and § 10 (g) (codified as General Statutes § 4-176 [g]) (referring to “a hearing…”
Fetto v. Sergi, 181 F. Supp. 2d 53 (D. Conn. 2001). · cites it 2× “At the Fettos’ timely request, an administrative hearing pursuant to Conn. Gen.Stat. § 4-176e before the DCF Ad *62 ministrative Hearings Unit relating to DCF’s services began in September 1997.”
Evans v. Tiger Claw, Inc., 61 A.3d 533 (Conn. App. Ct. 2013). · cites it 4× “Furthermore, neither the statutes pertaining to wage claim investigations nor the regulations promulgated by the department of labor require the department to hold a hearing under these circumstances.”
Speer v. Dept. of Agric., 192 A.3d 489 (Conn. App. Ct. 2018). · cites it 2× “Pursuant to General Statutes § 4-176e, hearings in contested cases in agency proceedings may be conducted before a hearing officer, who, pursuant to General Statutes § 4-179, renders a written, proposed final decision to the commissioner.”
1st All. Lending, LLC v. Dept. of Banking, 229 Conn. App. 664 (Conn. App. Ct. 2024). · cites it 2× “’’ General Statutes § 4-176e. violated the Connecticut SAFE Act even pursuant to the plaintiff’s own interpretation of MLO.”
Miller v. Dept. of Agric., 145 A.3d 393 (Conn. App. Ct. 2016). · cites it 2× “Pursuant to General Statutes § 4-176e, hearings in contested cases in agency proceedings may be conducted before a hearing officer, who, pursuant to General Statutes § 4-179, renders a written, proposed final decision to the commissioner.”
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