Town of Glastonbury v. Metro. Dist. Comm'n, 328 Conn. 326

Background

The Town of Glastonbury (plaintiff), a nonmember customer of the Metropolitan District Commission (MDC, defendant), sued for declaratory relief alleging MDC unlawfully imposed a "nonmember surcharge" on nonmember towns prior to Oct. 1, 2014.
MDC is a quasi-municipal corporation created by the General Assembly; its charter historically authorized supplying water to nonmember towns at rates "uniform with" district rates and allowed limited assessments for pipe connections and mains benefitting specific properties.
Beginning in 2011 MDC significantly increased a recurring nonmember surcharge that MDC described as allocating fixed/capital costs of the entire water utility (treatment, watershed, infrastructure) across nonmember customers.
In May 2014 the legislature enacted Special Act No. 14-21 amending MDC’s charter to expressly authorize certain nonmember surcharges (capping any surcharge to no more than the customer service charge); MDC argued the act mooted or validated past surcharges.
The trial court denied MDC’s motions to dismiss/strike, held S.A. 14-21 is not retroactive or merely clarifying, found the pre-2014 surcharge unlawful (exceeding MDC’s statutory authority), denied laches and other defenses, and granted Glastonbury summary judgment.
The Supreme Court affirmed, adopting the trial court’s comprehensive memorandum of decision.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Justiciability / Mootness (effect of S.A. 14-21)	S.A. 14-21 does not entitle MDC to retroactively validate prior surcharges; declaratory relief remains useful (and damages may follow).	S.A. 14-21 clarified/authorized surcharges and should be applied retroactively, rendering the claim moot.	S.A. 14-21 is not retroactive or purely clarifying; case remains justiciable because practical relief (declaration and potential recovery) is available.
Authority to impose surcharge (legality)	MDC lacked legislative authority before S.A. 14-21 to impose broad surcharges recovering systemwide capital/maintenance costs; its charter limited charges to water supply rates, pipe connections, and assessments benefiting specific property.	MDC had inherent or implied authority under its charter to impose the surcharge to equitably allocate fixed/capital costs.	MDC lacked express statutory authority to impose the systemwide nonmember surcharge pre-2014; the surcharge was illegal as a matter of law.
Laches / equitable defenses	N/A (Glastonbury sought declaratory relief for 2011–2014 surcharges; delay excusable given prior nominal amounts and sharp recent increases).	Long history of surcharges (dating to 1942) and late challenge prejudiced MDC; laches bars relief.	Delay was not unreasonable given small historical amounts and large recent increases; MDC failed to show prejudice; laches does not bar relief.
Joinder / standing / indispensable parties	Glastonbury has standing to seek declaratory relief for its own payments; the court may limit relief to plaintiff.	MDC argued nonmember towns/customers were indispensable and that relief would affect thousands of third parties.	Trial court properly proceeded; MDC’s broader joinder complaints were not preserved on appeal and Glastonbury has standing to pursue its claim.

Key Cases Cited

Valvo v. Freedom of Information Commission, 294 Conn. 534 (Conn. 2010) (justiciability/mootness principles)
McNally v. Zoning Commission, 225 Conn. 1 (Conn. 1993) (statutes are not retroactive absent clear legislative intent)
New Haven v. Public Utilities Commission, 165 Conn. 687 (Conn. 1973) (rule against retroactive application of statutes to pending actions)
Memphis Light, Gas & Water Div. v. Craft, 436 U.S. 1 (U.S. 1978) (declaratory relief and prospective/damages considerations)
Wright v. WoodridgeLake Sewer Dist., 218 Conn. 144 (Conn. 1991) (limitations on municipal/quasi‑municipal powers)
Romprey v. Safeco Ins. Co. of Am., 310 Conn. 304 (Conn. 2013) (summary judgment burden and standards)
Vendrella v. Astriab Family Ltd. P'ship, 311 Conn. 301 (Conn. 2014) (summary judgment standards)