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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agency’’ and to encourage people ‘‘to bring forth important
information . . . in order to protect . . . the proper run-
ning of our government’’); Conn. Joint Standing Com-
mittee Hearings, Government Administration and Elec-
tions, Pt. 2, 1998 Sess., p. 281, remarks of Attorney
General Blumenthal (value of whistleblowers is that
they ‘‘very simply are often the best watchdogs when
something goes wrong in state programs’’); 22 S. Proc.,
Pt. 17, 1979 Sess., p. 5648, remarks of Senator Clifton
A. Leonhardt (‘‘I think it’s very important that state
employees who come across malfeasance or inefficien-
cies or incompetence be encouraged to report these
[wrongdoings] to their superiors’’).
Second, since § 4-61dd was enacted in 1979, the legis-
lature has consistently extended the reach of the stat-
ute. See, e.g., Public Acts 1997, No. 97-55 (extending
coverage to employees of quasi-public agencies); Public
Acts 1998, No. 98-191, § 1 (protecting disclosures relat-
ing to large state contractors); Public Acts 2002, No. 02-
91, § 1 (adding rebuttable presumption to antiretaliation
provision); Public Acts 2011, No. 11-48, § 17 (extending
filing deadline for whistleblower complaints from thirty
days to ninety days). At no time has the legislature imposed
limitations on the statute’s coverage that would suggest
an intention to exclude employees.
Finally, because remedial statutes are construed broadly
to effectuate their purpose, exceptions to those statutes
should be construed narrowly. See, e.g., Commission
on Human Rights & Opportunities v. Edge Fitness,
LLC, 342 Conn. 25, 37, 268 A.3d 630 (2022). Section 4-
61dd does not contain an exception for state employees
who report their own errors, and there is no indication
in the legislative history of such an implied exception
to the phrase ‘‘[a]ny person’’ in § 4-61dd (a). Supplying
an exception, when not explicitly provided by the legis-
lature, for state employees who self-report would dilute
the efficacy of the statute by creating perverse incen-
Page 38 CONNECTICUT LAW JOURNAL June 11, 2024

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