346 Conn. 711
Conn.2023Background
- Clark was hired as a part‑time, uniformed firefighter by Waterford in 1992 after a physical showing no hypertension or heart disease; he became a full‑time firefighter in 1997.
- In 2017 Clark suffered a myocardial infarction and filed for heart‑disease/hypertension benefits under Conn. Gen. Stat. § 7‑433c.
- The town contested compensability, arguing § 7‑433c(b) bars benefits for persons who began employment on or after July 1, 1996, and that the term “member” in § 7‑433c must be read with the statutory definition in § 7‑425(5), which excludes persons who customarily work less than 20 hours/week.
- The commissioner awarded benefits without making a finding whether Clark had customarily worked 20+ hours/week while a part‑time firefighter; the Compensation Review Board and Appellate Court affirmed under a different statutory reading.
- The Connecticut Supreme Court reversed the Appellate Court: it held the § 7‑425(5) definition of “member” governs § 7‑433c eligibility (including the 20‑hour threshold) and remanded for factfinding on whether Clark met the 20‑hour requirement.
Issues
| Issue | Clark's Argument | Waterford's Argument | Held |
|---|---|---|---|
| Whether the word “member” in § 7‑433c is governed by the definition in § 7‑425(5) | “Member” should be given its ordinary meaning (so Clark, hired in 1992, qualifies); § 7‑433c does not incorporate § 7‑425(5) | § 7‑433c sits in the municipal retirement statutes; § 7‑425(5)’s definition (including the 20‑hour exclusion) controls eligibility | Court held § 7‑425(5) controls the meaning of “member” in § 7‑433c unless an explicit exception appears; therefore the 20‑hour rule applies |
| Whether applying § 7‑425(5) yields an absurd result (i.e., benefits only for employees of participating municipalities) | Applying § 7‑425(5) produces absurd and unfair results and was not the legislature’s intent | The text and placement of the statutes support applying § 7‑425(5); any policy concerns are for the legislature | Court rejected the absurdity claim, concluding application does not necessarily produce an absurd result and must follow the statutory text |
| Whether the commissioner erred by not making a factual finding whether Clark customarily worked 20+ hours/week pre‑1997 | No finding was necessary under the commissioner’s reading; Clark had long service and performed the same duties as full‑time firefighters | The commissioner must decide whether Clark satisfied the statutory 20‑hour criterion before awarding § 7‑433c benefits | Court held the commissioner used the wrong legal standard by not deciding the 20‑hour factual question and remanded for that finding |
| Proper interpretive approach to § 7‑433c (broad remedial vs. strict bonus construction) | § 7‑433c is remedial/beneficiary‑oriented and should be broadly construed in favor of claimants | § 7‑433c is special bonus legislation and eligibility provisions should be strictly applied | Court reaffirmed the remedial construction principle but held that unambiguous statutory definitions in the same part control the outcome |
Key Cases Cited
- Ciarlelli v. Hamden, 299 Conn. 265 (2010) (§ 7‑433c characterized as workers’ compensation‑style remedial legislation)
- Coughlin v. Stamford Fire Dept., 334 Conn. 857 (2020) (remedial construction of § 7‑433c and same benefit measurement as Workers’ Compensation Act)
- Holston v. New Haven Police Dept., 323 Conn. 607 (2016) (clarifying health‑related prerequisites in § 7‑433c)
- Genesky v. East Lyme, 275 Conn. 246 (2005) (interpretation of what constitutes a member of a paid municipal police department)
- Carriero v. Naugatuck, 243 Conn. 747 (1998) (treating § 7‑433c as special bonus legislation)
- Bergeson v. New London, 269 Conn. 763 (2004) (discussing § 7‑433c as distinct from a workers’ compensation award but procedurally administered through that system)
- Szudora v. Fairfield, 214 Conn. 552 (1990) (early recognition of remedial construction for § 7‑433c)