Connecticut General Statutes

Conn. Gen. Stat. § 4-180 (2026)

Contested cases. Final decision. Application to court upon agency failure

✓ current as of May 2026

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(a) Each agency shall proceed with reasonable dispatch to conclude any matter pending before it and, in all contested cases, shall render a final decision within ninety days following the close of evidence or the due date for the filing of briefs, whichever is later, in such proceedings.

(b) If any agency fails to comply with the provisions of subsection (a) of this section in any contested case, any party thereto may apply to the superior court for the judicial district of Hartford for an order requiring the agency to render a final decision forthwith. The court, after hearing, shall issue an appropriate order.

(c) A final decision in a contested case shall be in writing or orally stated on the record and, if adverse to a party, shall include the agency's findings of fact and conclusions of law necessary to its decision, including the specific provisions of the general statutes or of regulations adopted by the agency upon which the agency bases its decision. Findings of fact shall be based exclusively on the evidence in the record and on matters noticed. The agency shall state in the final decision the name of each party and the most recent mailing address, provided to the agency, of the party or his authorized representative. The final decision shall be delivered promptly to each party or his authorized representative, personally or by United States mail, certified or registered, postage prepaid, return receipt requested. The final decision shall be effective when personally delivered or mailed or on a later date specified by the agency.

(1971, P.A. 854, S. 15; P.A. 73-620, S. 17, 19; P.A. 75-529, S. 3, 4; P.A. 77-452, S. 46, 72; P.A. 78-280, S. 5, 127; P.A. 79-631, S. 23, 111; P.A. 88-230, S. 1, 12; 88-317, S. 17, 107; P.A. 90-98, S. 1, 2; P.A. 93-142, S. 4, 7, 8; P.A. 95-220, S. 4–6; P.A. 13-279, S. 2.)

History: P.A. 73-620 deleted detailed provisions for contents of final decision or order concerning findings of fact and conclusions of law; P.A. 75-529 added Subsecs. (a) and (b) and made former provisions Subsec. (c); P.A. 77-452 replaced court of common pleas with superior court, effective July 1, 1978; P.A. 78-280 replaced “Hartford county” with “the judicial district of Hartford-New Britain”; P.A. 79-631 made technical changes; P.A. 88-230 replaced “judicial district of Hartford-New Britain” with “judicial district of Hartford”, effective September 1, 1991; P.A. 88-317 amended Subsec. (a) by inserting “or the due date for the” and “, whichever is later”, amended Subsec. (b) by repealing provisions allowing any interested person to apply to superior court and repealing exception to requirement for court order if agency establishes to satisfaction of the court reasonable cause for failure to comply with Subsec. (a) and substantially amended Subsec. (c) re form, content, basis, delivery and effective date of final decisions in contested cases, effective July 1, 1989, and applicable to all agency proceedings commencing on or after that date; 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. 13-279 amended Subsec. (c) by adding “, including the specific provisions of the general statutes or of regulations adopted by the agency upon which the agency bases its decision”.

Failure to comply with former section requirements in sending plaintiff notice of final decision did not render defendant's action void. 168 C. 94. Cited. 171 C. 691; 172 C. 263; 173 C. 462; 186 C. 153; 191 C. 173; Id., 384; 204 C. 60; 207 C. 683; 210 C. 597; 220 C. 86; 228 C. 651; 232 C. 57; 233 C. 296; 234 C. 312; 239 C. 32.

Cited. 1 CA 1; 2 CA 689; 9 CA 622.

Cited. 43 CS 340; Id., 386; Id., 457; 44 CS 90.

Subsec. (c):

Cited. 205 C. 324. Oral decision of an agency discussed. 232 C. 181. Cited. 237 C. 209; 239 C. 437.

Cited. 37 CA 777.

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Notes of Decisions

Cited in 65 cases (5 in the last 5 years), 1975–2026 · leading case: Crest Pontiac Cadillac, Inc. v. Hadley, 685 A.2d 670 (Conn. 1996).

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Crest Pontiac Cadillac, Inc. v. Hadley, 685 A.2d 670 (Conn. 1996). · cites it 26× “The dispositive issue in this appeal is whether the mailing provisions of General Statutes § 4-180 (c) 1 are mandatory, such that an agency’s failure *439 to abide by those provisions tolls the time period in which an appeal of that agency’s decision must be filed.”

Jutkowitz v. Dep't of Health Servs., 596 A.2d 374 (Conn. 1991). · cites it 14× “to 1985) § 4-180 (a) and (b); (3) the plaintiff received a fair hearing and was not denied his right to due process of law; (4) Passero’s membership on the board was proper despite the fact that at the time of the hearings he was an officer of the Council of Chiropractic…”

Comm'n on Human Rights & Opportunities v. Windsor Hall Rest Home, 653 A.2d 181 (Conn. 1995). · cites it 26× “General Statutes § 4-180 (c) specifically provides that “[a] final decision in a contested case shall be in writing or orally stated on the record and, if adverse to a party, shall include the agency’s findings of fact and conclusions of law necessary to its decision. . . .” 7…”

Dep't of Pub. Saf. v. Freedom of Info. Comm'n, 930 A.2d 739 (Conn. App. Ct. 2007). · cites it 14× “” Likewise, General Statutes § 4-180 (a) provides that “[e]ach agency shall proceed with reasonable dispatch to conclude any matter pending before it and, in all contested cases, shall render a final decision within ninety days following the close of evidence or the due date for…”

Lee v. Bd. of Educ., 434 A.2d 333 (Conn. 1980). · cites it 3× “See General Statutes § 4-180 (Kev. to 1972). This language was deleted from the act in 1973.”

Ann Howard's Apricots Restaurant, Inc. v. Comm'n On Human Rights & Opportunities, 676 A.2d 844 (Conn. 1996). · cites it 3× “General Statutes § 4-180 (c) provides that “[t]he final decision shall be effective when personally delivered or mailed or on a later date specified by the agency.”

Packer v. Bd. of Educ., 717 A.2d 117 (Conn. 1998). · cites it 3× “” Because the defendant was required, pursuant to General Statutes § 4-180, to include in the record all findings of fact necessary to its determination to expel the plaintiff, we conclude that the defendant’s determination that the plaintiff had engaged in conduct “seriously…”

Fraenza v. Keeney, 655 A.2d 1113 (Conn. Super. Ct. 1994). · cites it 7× “In a letter to the commissioner dated September 18,1991, the plaintiffs attorney stated that “the applicant is preserving his objection to the decision based on the failure of the [department] to comply with the time deadlines set in C.G.S. § 4-180 (a).” Section 4-180 (a)…”

Pet v. Dep't of Health Servs., 638 A.2d 6 (Conn. 1994). · cites it 2× “It is fatal to the plaintiff’s claim of a due process violation that he failed to utilize the statutory remedies that were available to him to compel a prompt agency decision.”

Weems v. Citigroup, Inc., 961 A.2d 349 (Conn. 2008). · cites it 2× “This omission indicates a legislative intent that the provisions operate to secure order, system and dispatch in the proceedings.”

Burton v. Dept. of Env't Prot., 337 Conn. 781 (Conn. 2021). “to 2009) § 4-180, which affirmed the hearing officer’s proposed final decision, with minor modifications, and conducted an independent evaluation as to whether the permit complied with, among other statutes and regulations, CEPA and the Clean Water Act.”

Greater Bridgeport Transit Dist. v. State Bd. of Labor Relations, 653 A.2d 229 (Conn. Super. Ct. 1993). · cites it 7× “The transit district asserts that the board exceeded its authority in that it did not render its decision within *349 ninety days as required by General Statutes § 4-180 (a). 3 General Statutes (Rev.”

Show all 65 citing cases →

— Conn. Gen. Stat. § 4-180(a) — 2 cases

Dep't of Pub. Saf. v. Freedom of Info. Comm'n, 930 A.2d 739 (Conn. App. Ct. 2007). “” Likewise, General Statutes § 4-180 (a) provides that “[e]ach agency shall proceed with reasonable dispatch to conclude any matter pending before it and, in all contested cases, shall render a final decision within ninety days following the close of evidence or the due date for…”

Carroll v. Ragaglia, 292 F. Supp. 2d 324 (D. Conn. 2003).

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