Connecticut General Statutes

Conn. Gen. Stat. § 4-177 (2026)

Contested cases. Notice. Record

✓ current as of May 2026
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(a) In a contested case, all parties shall be afforded an opportunity for hearing after reasonable notice.

(b) The notice shall be in writing and shall include: (1) A statement of the time, place, and nature of the hearing; (2) a statement of the legal authority and jurisdiction under which the hearing is to be held; (3) a reference to the particular sections of the statutes and regulations involved; and (4) a short and plain statement of the matters asserted. If the agency or party is unable to state the matters in detail at the time the notice is served, the initial notice may be limited to a statement of the issues involved. Thereafter, upon application, a more definite and detailed statement shall be furnished.

(c) Unless precluded by law, a contested case may be resolved by stipulation, agreed settlement, or consent order or by the default of a party.

(d) The record in a contested case shall include: (1) Written notices related to the case; (2) all petitions, pleadings, motions and intermediate rulings; (3) evidence received or considered; (4) questions and offers of proof, objections and rulings thereon; (5) the official transcript, if any, of proceedings relating to the case, or, if not transcribed, any recording or stenographic record of the proceedings; (6) proposed final decisions and exceptions thereto; and (7) the final decision.

(e) Any recording or stenographic record of the proceedings shall be transcribed on request of any party. The requesting party shall pay the cost of such transcript. Nothing in this section shall relieve an agency of its responsibility under section 4-183 to transcribe the record for an appeal.

(1971, P.A. 854, S. 12; P.A. 73-620, S. 9, 10, 19; P.A. 88-317, S. 12, 107.)

History: P.A. 73-620 amended Subsec. (e) omitting statement of matters officially noticed, proposed findings and exceptions and staff memoranda or data submitted to hearing officer or agency members from record of contested case and amended Subsec. (f) to require party requesting transcript to pay its cost; P.A. 88-317 amended Subsec. (b) to require notice to be in writing, transferred provisions of former Subsec. (c) re opportunity to parties to respond and present evidence and argument to Sec. 4-177c, relettered former Subsec. (d) to Subsec. (c) and rephrased provisions of the subsection, relettered former Subsec. (e) to Subsec. (d) and amended Subsec. (e) to require notices, petitions, official transcript and proposed final decisions and exceptions and final decisions to be included in contested case record, relettered former Subsec. (f) to Subsec. (e) and amended Subsec. (e) by substituting “Any recording or stenographic record of the proceedings” for “Oral proceedings or any part thereof” and adding provision re agency responsibility to transcribe the record for an appeal, and transferred provisions of former Subsec. (g), which required findings of fact to be based exclusively on the evidence and on matters officially noticed, to Sec. 4-180, effective July 1, 1989, and applicable to all agency proceedings commencing on or after that date.

Notice of hearing under Sec. 10-151(b) which did not include two of the charges against the teacher held insufficient; findings of fact must be based on matters “officially noticed” as well as on the evidence. 167 C. 368. Cited. 171 C. 691; 172 C. 263; 173 C. 462; 176 C. 82; Id., 191; 177 C. 78; 183 C. 128; 186 C. 153; 188 C. 90; 191 C. 173; 207 C. 77; Id., 296; 208 C. 442; 210 C. 531; 211 C. 508; 213 C. 184; 214 C. 726; 215 C. 474; Id., 616; 223 C. 618; 228 C. 651; 239 C. 32.

Cited. 1 CA 1; 4 CA 117, 121; 9 CA 622; 33 CA 727; 34 CA 123; 37 CA 653; judgment reversed, see 238 C. 361. Notification by letter from complainant that requested information has been received, which was the same manner in which complainant initially notified commission of the contested case, constitutes a formal withdrawal of the complaint and therefore terminates commission's jurisdiction over the issue. 103 CA 571.

Administrative adjudication of no refund, not contested case. 30 CS 118. Cited. Id., 120; 34 CS 225; 39 CS 99; Id., 462; 41 CS 211; 42 CS 1; Id., 599.

Subsec. (b):

Subdiv. (4): Notice which failed to include several charges in “matters asserted” was prejudicial violation of Subsec. 167 C. 368. Cited. 174 C. 366. Subdiv. (2): Notice of hearing deemed legally sufficient where it cited statutory authorities of jurisdiction and under which violations claimed. 177 C. 515. Cited. 200 C. 489; 220 C. 86; 232 C. 57.

Cited. 22 CA 181; 41 CA 866.

Cited. 40 CS 226; 43 CS 340.

Notes of Decisions
Cited in 62 cases (2 in the last 5 years), 1973–2025 · leading case: Levinson v. Connecticut Bd. of Chiropractic Examiners, 560 A.2d 403 (Conn. 1989).
Levinson v. Connecticut Bd. of Chiropractic Examiners, 560 A.2d 403 (Conn. 1989). · cites it 12× “chiropractors) as distinguished from public members, and (2) each notice contained “a short and plain statement of the matters asserted” as required by General Statutes § 4-177 (b) (4). Concerning the evidence before the board with respect to Levinson, the trial court found that…”
Tele Tech of Connecticut Corp. v. Dep't of Pub. Util. Control, 855 A.2d 174 (Conn. 2004). · cites it 10× “In those cases, we sought to emphasize the difference between the notice requirements pertaining to the issuance of a license, which mandate only “a short and plain statement of the matters asserted”; General Statutes § 4-177 (b) (4); and the notice requirements relating to the…”
Goldstar Med. Servs., Inc. v. Dep't of Soc. Servs., 955 A.2d 15 (Conn. 2008). · cites it 7× “General Statutes § 4-177 (b) requires that notice of a contested hearing include the following: “(1) A statement of the time, place, and nature of the hearing; (2) a statement of the legal authority and jurisdiction under which the hearing is to be held; (3) a reference to the…”
Jutkowitz v. Dep't of Health Servs., 596 A.2d 374 (Conn. 1991). · cites it 7× “” We have held that the failure to raise a procedural claim or the failure to utilize a remedy available to cure a procedural defect can constitute a waiver of the right to object to the alleged defect.”
Dep't of Pub. Saf. v. Freedom of Info. Comm'n, 930 A.2d 739 (Conn. App. Ct. 2007). · cites it 8× “Pursuant to General Statutes § 4-177 (c), “[u]nless precluded by law, a contested case may be resolved by stipulation, agreed settlement, or consent order or by the default of a party.”
Martone v. Lensink, 541 A.2d 488 (Conn. 1988). · cites it 8× “*303 Moreover, as part of the Uniform Administrative Procedure Act (UAPA), § 4-181 must be read in the context of the rights to a hearing in contested cases and to judicial review of administrative decisions afforded by the act.”
Pet v. Dep't of Health Servs., 638 A.2d 6 (Conn. 1994). · cites it 5× “to 1985) § 4-177 (f). 21 We conclude that, in this case, the board improperly denied the plaintiff’s request to transcribe the relevant board meetings, since they were “oral proceedings” as contemplated by § 4-177 (f).”
Murphy v. Berlin Bd. of Educ., 355 A.2d 265 (Conn. 1974). · cites it 11× “General Statutes §§4-177 (a), (b) (1) and (4); 4-178 (1); and 4-177 (g).”
Connecticut Bus. & Indus. Ass'n v. Comm'n on Hospitals & Health Care, 573 A.2d 736 (Conn. 1990). · cites it 5× “Even if the mere filing of such a request were deemed to transform the proceeding before CHHC into a “contested case,” General Statutes § 4-177 (d) 5 expressly provides for a disposition of a contested case by an “agreed settlement,” the procedure followed by CHHC here.”
Concerned Citizens of Sterling, Inc. v. Connecticut Siting Council, 576 A.2d 510 (Conn. 1990). · cites it 5× “” General Statutes § 4-177 provides: “contested cases, notice, record.”
Leib v. Bd. of Examiners for Nursing, 411 A.2d 42 (Conn. 1979). · cites it 4× “That court dismissed that appeal and her appeal to this court followed.”
Connecticut Nat. Gas Corp. v. Pub. Utils. Control Auth., 439 A.2d 282 (Conn. 1981). · cites it 4× “” General Statutes § 4-177 (g). “[General Statutes] See.”
— Conn. Gen. Stat. § 4-177(c) — 2 cases
Dep't of Pub. Saf. v. Freedom of Info. Comm'n, 930 A.2d 739 (Conn. App. Ct. 2007). “Pursuant to General Statutes § 4-177 (c), “[u]nless precluded by law, a contested case may be resolved by stipulation, agreed settlement, or consent order or by the default of a party.”
Stuart v. Nappi, 443 F. Supp. 1235 (D. Conn. 1978).
— Conn. Gen. Stat. § 4-177(e) — 1 case
Connecticut Nat. Gas Corp. v. Pub. Utils. Control Auth., 439 A.2d 282 (Conn. 1981). “” General Statutes § 4-177 (g). “[General Statutes] See.”
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