Supreme Court of Connecticut

Patricia H. Mayfield v. Goshen Volunteer Fire Company, Inc.

August 2, 2011301 Conn. 739

Summary

The court affirmed dismissal of the labor commissioner’s inspection-warrant application because the volunteer fire company was not an employer covered by Connecticut’s Occupational Safety and Health Act. The court held that the statutory reference to the state and its political subdivisions has a plain and traditional meaning that does not include an independent nonprofit corporation, even one providing contracted fire protection and receiving substantial municipal support. The court also rejected importing the functional-equivalent test used under the Freedom of Information Act.