Robinson v. V. D. (2024)

Citation: Robinson v. V. D. (2024)
Parent Document: Robinson v. V. D. (2024)
Jurisdiction: Connecticut (state)
Effective Date: 2024-11-26
Original Source: https://www.courtlistener.com/opinion/10282961/robinson-v-v-d/ ↗

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added; internal quotation marks omitted.) Kruger v.
       Grauer, 173 Conn. App. 539, 547–48, 164 A.3d 764, cert.
       denied, 327 Conn. 901, 169 A.3d 795 (2017).
          In addition to the application of law to fact require-
       ment, our Supreme Court has identified additional fac-
       tors for courts to consider in determining whether a
       proceeding is quasi-judicial in nature. These factors
       include whether the body conducting the proceeding
       has the power to ‘‘(1) exercise judgment and discretion;
       (2) hear and determine or to ascertain facts and decide;
       (3) make binding orders and judgments; (4) affect the
       personal or property rights of private persons; (5) exam-
       ine witnesses and hear the litigation of the issues on a
       hearing; and (6) enforce decisions or impose penalties.
       . . . These factors are not exclusive; nor must all fac-
       tors militate in favor of a determination that a proceed-
       ing is quasi-judicial in nature for a court to conclude
       that the proceeding is, in fact, quasi-judicial. . . .
       [T]hese factors are [i]n addition to, not in lieu of, the
       application of the law to fact requirement.’’ (Citations
       omitted; internal quotation marks omitted.) Priore v.
       Haig, 344 Conn. 636, 648, 280 A.3d 402 (2022). It is also
       important for courts ‘‘to consider whether there is a
       sound public policy reason for permitting the complete
       freedom of expression that a grant of absolute immunity
       provides.’’ (Internal quotation marks omitted.) Id., 652.
         Our Supreme Court recently summarized that a pro-
       ceeding will only be considered quasi-judicial if ‘‘the
       proceeding at issue is specifically authorized by law,
       applies law to fact in an adjudicatory manner, contains
       adequate procedural safeguards, and is supported by a
       public policy encouraging absolute immunity for pro-
       ceeding participants.’’ Khan v. Yale University, 347
       Conn. 1, 10, 295 A.3d 855 (2023). Accordingly, ‘‘whether
       a particular proceeding is quasi-judicial in nature, for
       the purposes of triggering absolute immunity, will
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