North Branford Citizens Against Bulk Propane Storage v. North Branford

Citations

• 230 Conn. App. 335

Syllabus

The plaintiff, an association comprised of town residents who opposed the construction of a bulk propane storage facility in the town, appealed from the judgment of the trial court dismissing its declaratory judgment action against the defendants. The plaintiff claimed that the court erred in dismiss- ing the action on the ground that it failed to exhaust its administrative remedies. Held: This court affirmed the trial court's judgment dismissing the action on the alternative ground that the plaintiff lacked standing to maintain the action against the defendants, the plaintiff having failed to allege sufficient facts to establish that any of its individual members were aggrieved, as is required to establish associational standing. The plaintiff's allegation that certain actions by one of the defendants, a town official, violated the public trust, without any allegation of how that violation affected the plaintiff's individual members in a manner distinguish- able from those in the community as a whole, was insufficient to establish that the plaintiff's members were aggrieved. Argued October 10, 2024—officially released January 28, 2025