John J. Scinto v. R. David Stamm

Summary

The Supreme Court of Connecticut affirmed summary judgment for the Connecticut bar examining committee and its administrative director, holding that the committee's grading procedures—anonymous grading, calibrated model answers, score conversion, and automatic regrading of examinations within ten points of the passing score—are rationally connected to the state's substantial interest in assessing minimal competency to practice law and therefore satisfy due process. Applying the three-factor Mathews v. Eldridge balancing test, the court held that a failing bar applicant is not constitutionally entitled to a judicial hearing to regrade essay answers, given the existing procedural safeguards, the unlimited right to retake the examination, and the intolerable fiscal and administrative burden judicial regrading would impose. The court declined to review the sovereign-immunity special defense because the plaintiff was not aggrieved by the denial of his motion to strike it and the defendants did not raise it on appeal. No separate opinions were filed.