Idlibi v. Connecticut State Dental Commission

Citations

• 231 Conn. App. 171

Syllabus

The plaintiff, a dentist, appealed from the judgment of the trial court dismiss- ing his administrative appeal from the decision of the defendant finding that his failure to comply with sanctions imposed by a prior decision of the defendant rendered him unfit or incompetent during the period of noncompli- ance and ordering further disciplinary sanctions with respect to his dental license. The plaintiff claimed, inter alia, that the defendant lacked jurisdiction to suspend his dental license because it failed to provide him with sufficient notice of the facts warranting suspension prior to initiating summary suspen- sion proceedings. Held: The plaintiff's failure to file an administrative appeal to the Superior Court within forty-five days of the defendant's summary suspension of his dental license as required by the statute (§ 4-183 (c)) governing such appeals, deprived this court of subject matter jurisdiction to consider the merits of his claim. The trial court did not abuse its discretion in denying the plaintiff's motion for remand to introduce additional evidence before the defendant, as the additional evidence the plaintiff sought to present on remand was not suffi- ciently material to satisfy even the threshold requirements pursuant to § 4- 183 (h). The defendant's determination, as the governing medical board, that the plaintiff was unfit or incompetent during a period of noncompliance with sanctions that had been previously issued was reasonable and supported by sufficient evidence, and the defendant, in ordering additional sanctions against the plaintiff based on that determination, was acting under its express authority pursuant to statute (§ 20-114 (a) (2)). Argued November 20, 2024—officially released March 11, 2025