331 Conn. 404
Conn.2019Background
- Mangiafico owned a severely damaged, uninhabitable home in Farmington; town officials placed it on a blighted buildings list and imposed daily $100 fines.
- Municipal hearings reduced some fines but additional fines were later assessed; Mangiafico did not pay the fines or file the statutory § 7-152c(g) appeal to Superior Court.
- The town recorded two municipal liens for unpaid blight fines. Mangiafico sued in Connecticut Superior Court alleging § 1983 unconstitutional taking and due process violations, seeking injunctive relief, damages, and discharge of liens.
- Trial court dismissed most claims (including § 1983 claims) for lack of subject matter jurisdiction because Mangiafico failed to exhaust administrative remedies; Appellate Court affirmed.
- The Connecticut Supreme Court granted certification and addressed whether state administrative exhaustion is required before bringing § 1983 claims in state court and whether the Williamson County ripeness defense could be raised for the first time on appeal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether state administrative exhaustion is required before filing a § 1983 action in state court | Mangiafico: Patsy controls; exhaustion not required for § 1983, regardless of relief sought | Town: Connecticut precedent requires exhaustion, so dismissal for lack of jurisdiction was proper | Held: Patsy governs; exhaustion is not a prerequisite for § 1983 claims in state court; Connecticut precedents requiring exhaustion for injunctive relief (Pet and Laurel Park) overruled |
| Whether an injunctive § 1983 claim requires prior exhaustion as jurisdictional | Mangiafico: Even for injunctive relief, exhaustion is not jurisdictional; lack of adequate legal remedy is an element of injunctive relief, not jurisdiction | Town: Injunctive relief requires showing no adequate legal remedy (so exhaustion is prerequisite) | Held: Showing inadequacy of legal remedy remains an element of injunctive relief but is not jurisdictional; failure to plead it does not deprive court of jurisdiction |
| Whether the trial court properly dismissed § 1983 claims for lack of jurisdiction where plaintiff did not use § 7-152c(g) appeal | Mangiafico: Not required to appeal under § 7-152c(g) before filing § 1983 claim | Town: Failure to appeal deprived court of jurisdiction to hear federal claims | Held: Dismissal was improper; plaintiff need not exhaust administrative or judicial remedies before filing § 1983 claims in state court |
| Whether Williamson County ripeness (final decision) could be raised for first time on appeal | Mangiafico: Defendants did not preserve Williamson County below; it cannot be raised now | Town: Williamson County ripeness is jurisdictional and may be raised anytime | Held: Williamson County ripeness is prudential, not jurisdictional; defendants waived it by not raising it below, so court declined to address that defense on appeal |
Key Cases Cited
- Patsy v. Board of Regents, 457 U.S. 496 (1982) (exhaustion of state administrative remedies is not a prerequisite to a § 1983 action)
- Williamson County Regional Planning Commission v. Hamilton Bank, 473 U.S. 172 (1985) (ripeness rule: final decision and state compensation prongs for takings claims)
- Port Clinton Associates v. Board of Selectmen, 217 Conn. 588 (1991) (earlier Connecticut decision treating Williamson County finality as jurisdictional)
- Pet v. Department of Health Services, 207 Conn. 346 (1988) (held exhaustion required for injunctive relief under § 1983; overruled here)
- Laurel Park, Inc. v. Pac, 194 Conn. 677 (1984) (applied exhaustion requirement for injunctive § 1983 relief; overruled here)
- Felder v. Casey, 487 U.S. 131 (1988) (applied Patsy principles to state-court § 1983 actions)