Mangiafico v. State Board of Education, 138 Conn. App. 677

In December 2005 Mangiafico bought a Farmington property and moved his family there in February 2006, with mail, taxes, vehicle registrations, employment, and church attendance linking them to Farmington.
In June 2006, severe weather damaged the Farmington property, rendering it uninhabitable, and the family temporarily resided at their New Britain property, intending to return once repairs were possible.
The Farmington property remained uninhabitable and on the blighted building list; the family continued to reside in New Britain and did not establish a definite return date.
In September 2007, Mangiafico’s children began attending school in Farmington, but an investigation revealed they actually lived in New Britain, prompting a residency denial by the Farmington school board on January 8, 2009.
The school board held a hearing on February 24, 2009; on March 3, 2009 it determined the children were not Farmington residents and not entitled to free school accommodations.
Mangiafico appealed to the impartial hearing board, which on May 29, 2009 held that the children were not Farmington residents because they were not actually residing there, sustaining the denial of free school accommodations.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the hearing board correctly found lack of actual residence in Farmington	Mangiafico argues ties and intent to return support residency.	Board correctly required actual physical presence; indefinite absence defeats residency.	No abuse of discretion; no actual residence due to indefinite absence.
Whether there is a statutory exception to residency for displacement due to natural disaster	Displacement should be excused; McKinney-Vento protections may apply.	No statutory exception; residency requires presence; discretionary policies may consider disaster-related displacement.	There is no statutory disaster exception; residency not excused, but discretionary considerations exist.
Whether the defendant is estopped from relying on residency to deny accommodations	Reliance on residency proof and assurances about back tuition estop defendant.	Estoppel claims are highly fact-bound and inadequately developed in the record.	Review declined for lack of adequate record; not reviewed on this record.
Whether FOIA-obtained evidence should have been admitted to show disparate treatment	FOIA evidence would demonstrate that Farmington treated other families differently.	Evidence was insufficient to show pattern of disparate treatment; continuance denied appropriately.	Board did not abuse discretion; prior decisions and evidence supported denial of admission of such material.

Connecticut Motor Cars v. Commissioner of Motor Vehicles, 300 Conn. 617 (2011) (standard of review for agency findings; deference to agency on facts)
Lash v. Freedom of Information Commission, 300 Conn. 511 (2011) (deference to agency credibility determinations; substantial evidence standard)
Rapoport v. Zoning Board of Appeals, 301 Conn. 22 (2011) (substantial evidence review; cannot substitute weight of evidence for agency)
Dept. of Public Safety v. State Board of Labor Relations, 296 Conn. 594 (2010) (plenarly review when statute interpretation is not time-tested)