Interpreting Administrative Regulations–Part One

I hope everyone who celebrates Easter enjoyed the holiday!  Now, back to work.

Last Thursday the Connecticut Supreme Court issued its slip opinion in Sarrazin v. Coastal, Inc., a case concerning the circumstances under which an employee’s “travel time” between his home and work must be treated as compensable work time under state or federal wage and hour law.  The case is a must-read for employment lawyers, which I am not.  What attracted my interest was the Court’s discussion about how administrative regulations should be interpreted.  First, the Court stated that General Statutes section 1-2z–which codifies the “plain meaning rule”–applies to administrative regulations.  Second, it concluded that the State Department of Labor’s interpretation of its own administrative regulation (31-60-10) was not entitled to any judicial deference.

I respectfully dissent from both of these conclusions.  This post addresses the first issue, to wit, the relevance of section 1-2z to interpreting administrative regulations.  A subsequent post will address the issue of deference. Read the rest of this entry »