Salmon Brook Convalescent Home v. Commission on Hospitals & Health Care
In Salmon Brook Convalescent Home v. Commission on Hospitals & Health Care, 177 Conn. 356, 362, 417 A.2d 358 (1979) the state commissioner on hospitals and health care denied a rate increase requested by the convalescent home because it had violated certain compensation guidelines followed by the hospital commission. Id., 359-60.
The court struck down those "guidelines" as illegal regulations because they were applied as substantive rules, but had been not submitted for adoption under required UAPA procedures of notice and comment. Id., 361-64.