Interpreting Administrative Regulations–Part Two

In Part One of my two-part series on interpreting administrative regulations, I discussed my disagreement with the Connecticut Supreme Court’s position, set forth in Sarrazin v. Coastal, Inc., that General Statutes section 1-2z applies to administrative regulations–given that the plain language of 1-2z refers only to “statutes.”  In this post I discuss my disagreement with the Court’s position that an administrative agency’s interpretation of its own regulation is not entitled to any deference unless it is “time-tested, reasonable or the result of formal rule-making procedures.”

Read the rest of this entry »