194 Conn.App. 739
Conn. App. Ct.2019Background
- Paul Dombrowski, a retired New Haven police officer, agreed (without counsel) to a global workers’ compensation stipulation for $22,500; the city’s settlement committee approved the funds.
- On the morning of the stipulation-approval hearing, defendants’ counsel gave Dombrowski a separate "Settlement Agreement, General Release and Covenant Not to Sue" (not referenced in the stipulation) that waived many non–workers’ compensation claims (including ADEA claims); Dombrowski signed both documents after ~20–30 minutes of review.
- Commissioner Goldberg canvassed Dombrowski about the stipulation (using the Commission’s forms), found the stipulation knowingly and voluntarily executed, and approved it; Commissioner Goldberg did not review or sign the separate settlement agreement.
- Dombrowski received the $22,500 check, returned it, and then filed a motion to open the stipulation under Conn. Gen. Stat. § 31-315, claiming his execution of the settlement agreement was not knowing/voluntary and that the stipulation was therefore nugatory.
- Commissioner Salerno denied the motion to open (no evidence of fraud/mistake and canvass adequate) and concluded the commission lacked jurisdiction to adjudicate disputes over the settlement agreement; the Compensation Review Board affirmed, and the appellate court likewise affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Workers’ Compensation Commission has subject-matter jurisdiction to interpret/enforce terms of the separate settlement agreement waiving non–work‑comp claims | Dombrowski: commission can open the stipulation and address the settlement agreement’s enforceability | Defendants: settlement agreement is a separate contract; commission’s jurisdiction is limited to claims arising under the Workers’ Compensation Act | Held: No—commission lacks jurisdiction over contract issues unrelated to the Act; such disputes belong in another forum (Stickney, Leonetti applied) |
| Whether the stipulation should be opened under § 31-315 because Dombrowski’s execution of the settlement agreement was not knowing/voluntary | Dombrowski: he did not knowingly/willingly waive non‑work‑comp rights; canvass did not cover the settlement agreement | Defendants: Dombrowski was canvassed re: the stipulation, received the $22,500 consideration, and offered no evidence of fraud, mistake, or misrepresentation | Held: Denied—plaintiff failed to show fraud/mistake; canvass of stipulation was adequate and consideration was paid, so no statutory ground to open the stipulation |
| Whether Commissioner Goldberg erred by not reviewing or signing the separate settlement agreement at the stipulation hearing | Dombrowski: failure to have commissioner canvass him about the settlement agreement rendered the stipulation nugatory | Defendants: canvass and approval relate to the stipulation; commissioner need not adjudicate unrelated contractual waivers | Held: Commissioner’s canvass and approval of the stipulation were sufficient; commissioner was not required to adjudicate unrelated settlement‑agreement terms |
Key Cases Cited
- Stickney v. Sunlight Construction, Inc., 248 Conn. 754 (1999) (Workers’ Compensation Commissioner lacks subject‑matter jurisdiction over disputes requiring application of contract or insurance law beyond the Act)
- Leonetti v. MacDermid, Inc., 310 Conn. 195 (2013) (commission limited to deciding whether an agreement functions as an approved stipulation for workers’ compensation claims; other contract issues belong in another forum)
- Snyder v. Gladeview Health Care Center, 149 Conn. App. 725 (2014) (discussing stipulation approval process and that an approved stipulation is a binding award barring further compensation claims)