Idlibi v. Connecticut State Dental Commission
231 Conn. App. 171
Conn. App. Ct.2025Background
- Plaintiff, Dr. Ammar A. Idlibi, a dentist, was subject to disciplinary action by the Connecticut State Dental Commission in 2018 for failing to meet the standard of care in treating a child patient.
- The Commission ordered sanctions: a $10,000 civil penalty, a public reprimand, and a three-year probation with specific conditions (mandatory courses, practice supervision, and monitoring).
- Plaintiff appealed the 2018 Commission order, but failed to comply with the conditions while the appeal was pending.
- In 2019, the Commission summarily suspended Idlibi’s license for noncompliance; after eventual compliance, the suspension was lifted but further sanctions were imposed.
- Plaintiff filed an administrative appeal to the Superior Court contesting the Commission's authority, process, and evidentiary basis for further discipline; the court dismissed the appeal, and Idlibi appealed again.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Jurisdiction for Summary Suspension | Commission lacked jurisdiction due to inadequate notice before suspension | Appeal not timely filed | Court lacked subject matter jurisdiction due to Idlibi’s failure to timely appeal summary suspension |
| Remand for Additional Evidence | Court erred in not allowing new evidence regarding later Commission findings | Evidence not material | No abuse of discretion; new evidence immaterial to disposition |
| Commission’s Decision Supported by Substantial Evidence | No rational connection between belated compliance and finding of incompetence | Decision reasonable | Commission had authority and sufficient evidence to deem noncompliance as unfit/incompetent |
| Arbitrary & Capricious/ Due Process (subsidiary argument) | Decision was arbitrary, capricious, violated due process | UAPA meets due process | Claim inadequately briefed; UAPA provides sufficient safeguards |
Key Cases Cited
- Peters v. Dept. of Social Services, 273 Conn. 434 (Subject matter jurisdiction over agency appeals)
- Markley v. State Elections Enforcement Commission, 339 Conn. 96 (Statutory deadlines control appellate jurisdiction)
- Miko v. Commission on Human Rights & Opportunities, 220 Conn. 192 (Agency decisions reviewed for substantial evidence)
- Altholtz v. Dental Commission, 4 Conn. App. 307 (Deference to medical boards’ professional standards)