Section 4-61dd

Citation: Section 4-61dd
Parent Document: Dept. of Public Health v. Estrada, 349 Conn. 223 (2024)
Jurisdiction: Connecticut (state)
Effective Date: 2024-06-11
Original Source: https://www.courtlistener.com/opinion/10131752/dept-of-public-health-v-estrada/ ↗

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only three enumerated contexts, namely, in (1) ‘‘any
       state department or agency,’’ (2) ‘‘any quasi-public agency,’’
       or (3) ‘‘any large state contract . . . .’’ General Statutes
       (Rev. to 2017) § 4-61dd (a). Because municipalities are
       not included in this list, the department contends that
       the protections of § 4-61dd are not applicable in this
       case. The commission contends that § 4-61dd applies
       to purported misconduct in municipal government in
       situations in which the state is ‘‘substantially involved.’’
       The commission also contends, however, that we need
       not reach this issue because the error reported by Estrada
       to Blaschinski was that the department, a state agency,
       erred in approving Wang for the position of acting direc-
       tor of health. We agree with the commission that we
       need not reach this issue.
          Although Wang may have misrepresented his creden-
       tials on his resume, which would have amounted to
       misconduct at the municipal level, the record is clear
       that Estrada reported wrongdoing by the department—
       namely, its deficient review process of an appointee’s
       credentials and its erroneous approval of Wang—and
       her own failure to verify that Wang had the degree he
       claimed to have on his resume. The referee found that
       Estrada had ‘‘told [Blaschinski] that Wang did not pos-
       sess the proper credentials to be interim director of
       health, which violated . . . § 19a-200.’’ Whether Estrada
       was reporting her own error in failing to ensure Wang’s
       credentials were accurate or revealing that the depart-
       ment had no policy to guide the review of credentials
       for prospective acting directors of health, Estrada’s dis-
       closure concerned the misconduct of a state depart-
       ment and/or employee—even if there was also
       misconduct by Wang at the municipal level.6 Any error
         6
          The department’s one page analysis of this issue does not address why
       Estrada’s failure to investigate or the department’s failure to have a policy
       does not amount to allegations of misconduct of a state department or
       employee.
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