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![handle is hein.sag/sagct0011 and id is 1 raw text is: 1992 Formal Opinion, Attorney General of Connecticut
Attorney General's Opinion
Attorney General, Richard Blumenthal
January 7, 1992
Jon M. Alander
Commissioner
Department of Human Resources
1049 Asylum Avenue
Hartford, CT 06105
Dear Commissioner Alander:
This is in response to your request for a formal opinion of the Attorney General, submitted in your capacity as
Chairman of the Commission For Child Support Guidelines, on the following two questions:
(1) Whether the child support guidelines, promulgated on January 1, 1991, are subject to the legislative review
provisions of Public Act 91-209; and
(2) Whether the January 1, 1991 child support guidelines, and all future guidelines, are subject to the rule-
making procedures under the Uniform Administrative Procedure Act.
For the reasons which follow, we answer each of the Commission's questions in the negative.
Public Act 91-209
The Child Support Guidelines promulgated by the Commission For Child Support Guidelines on January 1,
1991 (1991 Guidelines), were developed pursuant to 1989 Conn.Pub.Acts 89-203, § 1, An Act Concerning
Child Support Guidelines. For purposes relevant to your inquiry, that legislation provided:
The commission for child support guidelines is established to review the child support guidelines ...
[promulgated by its predecessor commission] ... and to issue updated guidelines not later than January 1, 1991
and every four years thereafter ... (Emphasis added)
The Commission satisfied the mandate of 1989 Conn.Pub.Acts 89-203, and issued updated guidelines on
January 1, 1991. However, recognizing that time would be needed to ensure a smooth transition from the old
to the new guidelines, the Commission provided for a three (3) month delay between the guidelines' issuance
and implementation dates, stating in the Guidelines document itself:
The updated guidelines issued on January 1, 1991 ... shall be effective March 1, 1991. This ... [delay] ... to
allow the Commission ... to ensure a successful and uniform transition ... (Emphasis added)
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