Mayfield v. GOSHEN VOLUNTEER FIRE CO., INC., 22 A.3d 1251

Mayfield sought a warrant to inspect Goshen Volunteer Fire Company to assess OSHA compliance; fire company is an independent nonprofit corporation with volunteer members who receive no salary but may obtain workers’ compensation via the town.
The town provides financial support and may terminate the oral contract for fire protection; the town leases land and building to the fire company for $1/year, and funds town assets such as vehicles.
The trial court dismissed the warrant application as outside the act’s coverage because § 31-367(d) limits the employer to the state and its political subdivisions; the commissioner appealed.
The commissioner contends the fire company is either a covered employer by virtue of being an agency of a political subdivision or via the “functional equivalent” test used for FOIA public agencies; the fire company contends the plain meaning of political subdivision excludes it.
The appellate court reviews de novo, focusing on statutory construction to determine whether the fire company falls within § 31-367(d)’s definition of employer as the state or a political subdivision; the court ultimately agrees with the trial court.
The court notes the act mirrors federal OSHA with respect to jurisdiction and declines to adopt the functional equivalent approach or to extend coverage to nonprofit fire companies absent explicit statutory language.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the fire company is an employer under §31-367(d).	Mayfield argues the fire company is an agency or under the functional equivalent of a political subdivision.	Goshen Fire Company contends it is not a political subdivision and thus not an employer under §31-367(d).	No; the fire company is not a political subdivision and not an employer under §31-367(d).
Whether the commissioner may apply the FOIA functional equivalent test to include the fire company.	Mayfield urges applying the functional equivalent test to treat the fire company as a public agency.	Goshen Fire Company opposes importing the FOIA test into OSHA coverage.	No; no meaningful relationship between FOIA’s test and the act justifies adopting it.
Whether federal OSHA context supports extending coverage to the fire company.	Mayfield relies on alignment with federal standards to justify coverage.	Goshen Fire Company argues the plain statutory text controls and federal analogies do not compel extension.	No; the plain text excludes the fire company, and federal analogies do not alter the state’s statutory definition.
Whether the result is absurd and thus justifies expansion of coverage.	Mayfield asserts coverage is necessary due to dangerous work.	Goshen Fire Company contends absurdity is not warranted to override the text.	Absence of absurdity in the text; expansion not shown by policy concerns alone.

Pasquariello v. Stop & Shop Cos., 281 Conn. 656 (2007) (statutory construction guiding interpretation of broad terms)
State ex rel. Maisano v. Mitchell, 155 Conn. 256 (1967) (definition of political subdivision and local government entities)
Dugas v. Beauregard, 155 Conn. 573 (1967) (attributes of political subdivision in traditional sense)
Board of Trustees v. Freedom of Information Commission, 181 Conn. 544 (1980) (functional equivalent test origin in FOIA context)
Connecticut Humane Society v. Freedom of Information Commission, 218 Conn. 757 (1991) (criteria for determining public agency status; functional equivalence framework origin)