Lawson v. Commissioner of Motor Vehicles, 134 Conn. App. 614

Lawson was arrested for operating a vehicle under the influence and informed of implied-consent/sobriety testing; he refused tests.
Derby police forwarded a report of his refusal to the DMV, which initiated license-suspension proceedings.
A DMV administrative hearing found probable cause, noted refusal of sobriety tests, and suspended Lawson’s license for six months.
Lawson petitioned for reconsideration; DMV denied the petition; he filed a recognizance bond in the Superior Court but did not file an administrative appeal within 45 days.
Lawson later filed his appeal on November 27, 2009, after the 45-day deadline had expired, arguing that filing occurred when he paid the bond.
The trial court determined it lacked subject matter jurisdiction because the appeal was untimely, and the court affirmed the judgment on appeal to the Connecticut Appellate Court.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court lacked jurisdiction due to § 4-183(c) deadline.	Lawson argues timely filing occurred with the recognizance bond.	DMV asserts filing occurred November 27, 2009, after the deadline.	Yes; jurisdiction lacked; filing was untimely.
Whether filing via recognizance bond constitutes proper filing of the appeal.	Bond hand‑off constitutes filing.	Filing did not occur via bond; must file with clerk.	No; bond did not constitute filing.
Whether the court erred in evaluating evidence supporting untimely filing.	Affidavit supported timely filing.	Court could weigh evidence and found untimely.	No clear error; court’s finding supported by record.

Hefti v. Commission on Human Rights & Opportunities, 61 Conn.App. 270 (2001) (strict compliance required for administrative appeals)
Murtha v. Hartford, 303 Conn. 1 (2011) (great deference to trial court on factual findings; review for clear error)
PHH Mortgage Corp. v. Cameron, 130 Conn.App. 238 (2011) (when jurisdiction lacking, discussion of merits is dicta)