Prendergast. v. Commissioner of Motor Vehicles, 160 A.3d 1087

Hart Prendergast was arrested for operating a motor vehicle under the influence after a late-night incident in Hamden on Route 15, with Dorelus observing signs of intoxication and a temporal nexus to a prior collision.
At the scene, Prendergast was found in a parked, damaged blue Nissan Altima with four flat tires, vomit on his collar, and an odor of alcohol; he also failed one field sobriety test and refused two others.
He was arrested around 12:45 a.m. for OUI; at the police station he refused a breath test for alcohol.
The Department of Motor Vehicles held hearings on May 6 and May 27, 2015, determining probable cause to arrest, whether he refused testing, and whether to suspend his license under § 14-227b; the hearing officer suspended for one year based on prior suspension and other findings.
Prendergast appealed under § 4-183, challenging the sufficiency of evidence for probable cause and the hearing officer’s continuation to subpoena officers; the trial court upheld the decision and dismissed the appeal.
The court applied the substantial evidence standard under the Uniform Administrative Procedure Act and concluded there was substantial evidence of probable cause and that due process was not violated by subpoenaing officers after the proceeding had rested.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was there probable cause to arrest for operating under the influence?	Prendergast argues no temporal nexus and insufficient evidence.	DMV asserts substantial evidence supports probable cause given odor, appearance, and nexus to accident.	Probable cause established; evidence supported nexus between liquor and operation.
Did the hearing officer violate due process by continuing to subpoena officers after the defendant rested his case?	Continuation after resting denied due process and right to a fair hearing.	Continuance authorized by statute and regulations to obtain necessary evidence; hearings are informal.	No due process violation; continuance permitted and hearing properly reinstated.

Murphy v. Commissioner of Motor Vehicles, 254 Conn. 333 (Conn. 2000) (probable cause analysis and temporal nexus guiding administrative review)
State v. Dunbar, 51 Conn. App. 313 (Conn. App. 1998) (administrative hearings may present evidence after rest of case)
State v. DeCoster, 147 Conn. 502 (Conn. 1960) (temporal nexus between intoxication and operation in criminal context)
Murphy v. Commissioner of Motor Vehicles, 254 Conn. 333 (Conn. 2000) (as above (listed again for attribution consistency))
State v. Lee, 138 Conn. App. 420 (Conn. App. 2012) (operating encompasses broader conduct than driving; requires not direct evidence)
Santiago v. Commissioner of Motor Vehicles, 134 Conn. App. 668 (Conn. App. 2012) (administrative hearings are informal; not governed by strict evidence rules)