The Connecticut Appellate Court recently ruled in the case of Abbas Mohammadi et al. v. William M. Tong et al. (AC 47598), affirming the dismissal of claims made by a dentist and his associated entities against state officials. The court's decision, released on September 29, 2026, centers on the implications of a press release issued by the state attorney general regarding a settlement agreement related to alleged billing irregularities. This ruling is significant as it addresses the balance between public accountability and individual reputations, particularly in the context of qualified immunity for government officials.
The plaintiffs, Abbas Mohammadi, Columbia Dental, P.C., and Columbia Oral Maxillofacial Imaging, LLC, had previously settled claims with state and federal governments concerning billing irregularities. Following this settlement, the plaintiffs alleged that a press release issued by the defendants, including Attorney General William Tong and former Department of Social Services Commissioner Deidre Gifford, contained false information that damaged their reputations. The plaintiffs argued that this press release violated their rights under federal law, specifically 42 U.S.C. § 1983, which protects individuals from state actions that infringe upon their constitutional rights.
The dispute arose after Brittany Ames Mahoney, a former employee of Columbia Dental, filed a qui tam complaint alleging that the plaintiffs submitted false claims to the Medicaid program. This led to a joint investigation by state and federal authorities, culminating in a settlement where the plaintiffs agreed to pay $300,000 without admitting liability. The press release, which detailed the settlement and the allegations, prompted the plaintiffs to file their lawsuit, claiming reputational harm and violations of their rights.
In its ruling, the Connecticut Appellate Court upheld the trial court's decision to dismiss the plaintiffs' claims, emphasizing the concept of qualified immunity. The court found that the plaintiffs had waived their argument regarding the procedural appropriateness of the defendants' motion to dismiss, as they did not object during the trial. The court stated, "The plaintiffs waived their claim that a motion to dismiss was not the proper procedural vehicle for the defendants to use in asserting qualified immunity as a defense to the claims against them under 42 U.S.C. § 1983." This ruling highlights the importance of procedural adherence in legal disputes.
The court further concluded that the plaintiffs failed to demonstrate that the defendants' actions constituted a deprivation of their constitutional rights. Specifically, the court noted that the plaintiffs did not show that the press release imposed a state burden or altered their professional status, which is necessary to support a claim under the stigma-plus theory of procedural due process. The court remarked, "The state, through the actions of the defendants, did nothing to impose any further burden upon the plaintiffs, nor did they create an alteration of the plaintiffs' status which would satisfy the 'plus' requirement."
Additionally, the court addressed the plaintiffs' claims under the Lanham Act, which prohibits false advertising, stating that the press release did not qualify as a commercial advertisement. The court determined that the plaintiffs did not plead sufficient facts to establish that the press release was intended to influence consumer behavior, leading to the dismissal of that count as well.
The impact of this ruling extends beyond the immediate parties involved. By affirming the dismissal of the plaintiffs' claims, the court reinforced the doctrine of qualified immunity, which protects government officials from liability for actions taken in their official capacity, as long as those actions do not violate clearly established statutory or constitutional rights. This case serves as a reminder of the challenges individuals face when seeking redress against state actors, particularly in matters involving public statements and reputational harm.
Moving forward, this ruling may influence how public officials communicate about settlements and allegations involving private entities. It underscores the need for careful consideration of the language used in public statements to avoid potential legal challenges. The plaintiffs in this case may consider appealing the decision to the Connecticut Supreme Court, although details regarding any potential appeal were not available in the court filing.
In summary, the Connecticut Appellate Court's ruling in Mohammadi v. Tong emphasizes the complexities surrounding qualified immunity and the challenges faced by individuals seeking to hold government officials accountable for their public statements. This case highlights the delicate balance between transparency in government actions and the protection of individual reputations.