of absolute immunity that “[buttress] the principle of the
separation of powers”; Office of the Governor v. Select
Committee of Inquiry, supra, 271 Conn. 561; see also,
e.g., id., 560–65 (immunity from judicial review under
speech or debate clauses of federal and state constitu-
tions); or that “safeguard the essential character and
function” of a branch of government, consistent with
separation of powers principles; Jamie G. v. Dept. of
Children & Families, 352 Conn. 736, 754–55, 339 A.3d
598 (2025); see also, e.g., id., 748–49, 754–55 (discuss-
ing common-law judicial and quasi-judicial immunities);
the immunity discussed here reflects a recognition that
a forum’s exercise of jurisdiction is void ab initio when
it violates the separation of powers doctrine. Cf. Office
of the Governor v. Select Committee of Inquiry, supra,
580 (“the legislature . . . engage[s] in the impeachment
process in order to vindicate the separation of powers
provision”).
Given the relationship between the separation of pow-
ers doctrine and the various immunities from suit, the
Judicial Branch has satisfied the requirement of § 4-183
(b) that its claim of immunity from suit be at least “col-
orable”; Stamford v. Commission on Human Rights &
Opportunities, Office of Public Hearings, supra, 351
Conn. 314 n.12; for that claim to receive interlocutory
appellate review in the Superior Court. Dismissal of
the Judicial Branch’s interlocutory appeal asserting
this colorable claim of immunity from suit would have
resulted in an irrevocable loss of that immunity for the
Judicial Branch in the administrative forum, which is
a situation that § 4-183 (b) is intended to prevent. See,
e.g., Trinity Christian School v. Commission on Human
Rights & Opportunities, supra, 329 Conn. 693.
For these reasons, the Judicial Branch’s invocation of
immunity from the administrative proceedings, derived
from the separation of powers doctrine, is a colorable
claim that satisfies the second prong of § 4-183 (b) and
conferred interlocutory appellate jurisdiction on the
trial court.
State of Connecticut, Judicial Branch v. Commission on Human Rights &
Opportunities, Office of Public Hearings