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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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
at the city’s level did not obviate the department’s obli-
gation to review Wang’s credentials or the department’s
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.
June 11, 2024 CONNECTICUT LAW JOURNAL Page 35

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