Gentile-Riaz v. Samo Thraki, LLC (2025)

Citation: Gentile-Riaz v. Samo Thraki, LLC (2025)
Parent Document: Gentile-Riaz v. Samo Thraki, LLC (2025)
Jurisdiction: Connecticut (state)
Effective Date: 2025-12-16
Original Source: https://www.courtlistener.com/opinion/10758261/gentile-riaz-v-samo-thraki-llc/ ↗

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considers factual predicate for claims), cert. denied,
       328 Conn. 937, 184 A.3d 267 (2018).
          We note that an identified primary policy underlying
       the exhaustion doctrine would not be served by requir-
       ing the plaintiff to pursue her claim through OSHA. Our
       Supreme Court has explained that ‘‘a primary purpose
       of the [exhaustion] doctrine is to foster an orderly pro-
       cess of administrative adjudication and judicial review,
       offering a reviewing court the benefit of the agency’s
       findings and conclusions. It relieves courts of the bur-
       den of prematurely deciding questions that, entrusted
       to an agency, may receive a satisfactory administrative
       disposition and avoid the need for judicial review. . . .
       Moreover, the exhaustion doctrine recognizes the
       notion, grounded in deference to [the legislature’s] dele-
       gation of authority to coordinate branches of [g]overn-
       ment, that agencies, not the courts, ought to have pri-
       mary responsibility for the programs that [the legislature]
       has charged them to administer. . . . Therefore,
       exhaustion of remedies serves dual functions: it pro-
       tects the courts from becoming unnecessarily burdened
       with administrative appeals and it ensures the integrity
       of the agency’s role in administering its statutory
       responsibilities.’’ (Internal quotation marks omitted.)
       Financial Consulting, LLC v. Commissioner of Ins.,
       315 Conn. 196, 212–13, 105 A.3d 210 (2014). Similarly,
       our appellate courts have stated that ‘‘one purpose
       underlying the exhaustion doctrine is that judicial
       review may be hindered by the failure of the litigant to
       allow the agency to make a factual record, or to exercise
       discretion or apply its expertise.’’ (Internal quotation
       marks omitted.) Fitzgerald v. Bridgeport, 187 Conn.
       App. 301, 318, 202 A.3d 385 (2019); see also Stepney,
       LLC v. Fairfield, 263 Conn. 558, 568, 821 A.2d 725 (2003)
       (policies underlying exhaustion doctrine were best
       served by requiring plaintiff to take claim before
       agency’s commissioner, where issue involved fact
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