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******************************************************TODD GAGLIARDIv. COMMISSIONER OF CHILDREN AND FAMILIES (AC 36421)
Keller, Mullins and Bear, Js.
Submitted on briefs January 9—officially released March 3, 2015

(Appeal from Superior Court, judicial district of New

Britain, Prescott, J.)
William B. Westcott filed a brief for the appellant (plaintiff). George Jepsen, attorney general, andJohnE. Tucker andBenjaminZivyon, assistantattorneysgeneral, fileda brief for the appellee (defendant).Opinion KELLER, J. The plaintiff, Todd Gagliardi, appeals from thejudgment rendered by the trial court dismissing his appeal from an administrative decision of the Commissionerofthe DepartmentofChildrenandFamilies (commissioner) that substantiated claims of child sexual abuse committed by the plaintiff against G.M.,1 and placed the plaintiff’s name on the commissioner’s child abuse and neglect central registry (registry). On appeal, the plaintiff claims that the court erred in dismissing his appeal from that administrative decision by erroneously concluding that an exhibit containing text messages admitted during the plaintiff’s substantiation hearing was sufficiently authenticated. We affirm the judgment of the court.
The following facts, as set forth by the trial court, and procedural history are relevant here. ‘‘In May 2012, G.M. was a sixteen year old junior at Branford High School. The plaintiff

. . . was a teacher at Branford High School, and had been G.M.’s Spanish teacher during her freshman year. Between May 26 and May 31, 2012, the plaintiff exchanged text messages of an increasingly sexualnature with G.M. The textmessages include graphic descriptions ofvarious sexual acts that G.M. and the plaintiff [purportedly] wanted to perform

on each other and of sexual activities that they had engaged in with others. The plaintiff and G.M. did not have anyphysical contact duringthis weeklongperiod. ‘‘G.M.’s mother ‘periodicallypulls’ her daughter’s cell phonerecords. OnMay31, 2012, G.M.’smotherobtained [G.M.’s] text message history from her cell phone provider and discovered the texts between G.M. and the plaintiff. G.M.’s mother reported the texts to the school and provided copies ofthe transcribed messages to the Branford Police Department. The police then provided

a copy of the transcript to [an investigator working for the commissioner, Shanelle] Ingram. G.M. admitted sending text messages to the plaintiff. [The commissioner] and the Branford Police Department completed

a joint investigation, but criminal charges against the plaintiff were not filed because G.M.’s mother did not want to press charges, no physical contact had occurred, and the plaintiffhad resigned from his teaching position.
‘‘In July 2012, the plaintiff received notice that the [commissioner] had completed [the] investigation and had substantiated the allegations against him. The notice further informed the plaintiff that [the commissioner] deemed him a risk to the safety ofchildren, and recommendedthathisnamebeplacedonthe [registry].2 Theplaintiffrequested additional review ofthe findings in accordance with General Statutes § 17a-101k (b) and (c). ‘‘On August 27, 2012, [the commissioner] notified theplaintiffthat [she] hadconductedaninternalreviewand had chosen to uphold [her] findings. At the plaintiff’s request, [the commissioner] then held a substantiation hearing on November 29, 2012. Although he was represented by counsel at the hearing, the plaintiff decided not to personally attend. At the hearing, a transcript of text messages that were sent by the plaintiff and G.M. to each other was admitted into evidence. The hearing officer, by relying on the content of the text messages themselves and otherevidenceinthe record, concluded that the text messages were sufficiently authenticated and admitted them into evidence. ‘‘[The commissioner] issued a final written decision

on January 18, 2013, upholding the substantiation of sexual abuse andthe plaintiff’splacement onthe [registry]. The [hearing officer’s] decision was based primarily on the sexual content of the text messages, which

were furnished by G.M.’s mother, who obtained them from [the cell] phone company. The [hearing officer] reasoned that ‘[t]he content of the text messages betweenthe [plaintiff] and [G.M.] supportsthe [commissioner’s] finding that the [plaintiff] sexually exploited her through grooming behavior designed to result in
more intimate sexual conduct.’ ’’ (Footnotes altered.)
Pursuant to General Statutes § 4-183,3 the plaintiff appealed from the commissioner’s administrative decision to the trial court on the basis ofhis claim that the text messages at issue were improperly admitted as evidence before the hearing officer because they were not sufficiently authenticated to prove that he had authored them.
The court dismissed the plaintiff’s appeal. At the outset, the court emphasized that administrative tribunals

are notboundbythe ConnecticutCode ofEvidence and mayconsiderhearsayin determiningthe authenticityof exhibits that would be inadmissible under the rules of evidence so longasthe exhibits are ‘‘reliable, probative, material, and not unduly repetitious.’’ The court acknowledged that the text messages were authenticated primarily on the basis of their content, which contained multiple layers of hearsay. Despite this, the court found that the text messages were trustworthy and reliable for three reasons. First, the court rejected the notion that the lengthy chain ofcustody ofthe text message records rendered them untrustworthy. According to the court, the text message records were transferred from (1) the company providing G.M.’s cell phone service to (2) G.M.’s mother, who transferred them to (3) the police, who transferred them to (4) the commissioner. The court found that the plaintiff had not alleged that any ofthe foregoing parties altered the records or had a motive to do so. Therefore, the court refusedto conclude thatthe lengthychain ofcustodyof the records, withoutmore, underminedtheirreliability. Second, the court agreed with the hearing officer’sfinding that the record contained no evidence suggestingthat G.M. had anyreasonto fabricate the allegations raised against the plaintiff. The court noted that G.M. admitted to the exchange of text messages between herself and the plaintiff only after her mother discoveredthetextmessages. Further,thecourtemphasized the hearing officer’s finding that there was no evidence presented suggesting that G.M.’s mental state
was impaired or impacted the reliability of the statements concerning the text messages that she provided to Ingram during Ingram’s investigation. Third, the court found that the content of the text messages was sufficient to authenticate the plaintiffas their author. The court noted that text messages may be authenticated by circumstantial evidence of ‘‘ ‘distinctive characteristics’ ’’ within the text messages that identifythe author. The courtlistedthe following ‘‘ ‘distinctive characteristics’ ’’ contained in the text messages that sufficiently authenticated the identity ofthe author of the text messages as the plaintiff: (1) the sender identified himselfas a Spanish teacher at G.M.’s school; (2) themessages containedflirtingandrepeated warnings aboutthe needforsecrecy, ‘‘exactlywhat one would expect from a teacher attempting to establish a sexual relationship with a student’’; and (3) many of the text messages focused on various articles of clothing that the plaintiff and G.M. wore at school.
In addition, the court rejected the plaintiff’s claims that (1) someone pretending to be the plaintiffsent the text messages, (2) there was no evidence connecting the plaintiff’s cell phone account with the cell phone number that sent the text messages to G.M., and (3) there was no corroborating evidence of an inappropriate relationship between the plaintiff and G.M. The court found that the plaintiff failed to introduce any evidence in support of the first two claims. Moreover, the court stated that, in any event, the commissioner didnot have the burden atthe substantiation hearingto rule out everypossible inconsistencywith authenticity. Lastly, the court found that the plaintiff had conceded that, if the text messages were properly authenticated and admitted, then the hearing officer had substantial evidence to support her decision.
For the foregoing reasons, the court concluded that the hearing officer did not abuse her discretion by admitting the text messages into evidence and dismissed the plaintiff’s appeal. This appeal followed.
The plaintiffclaims thatthe court erred in dismissing his appeal from that administrative decision because thecourterroneouslyconcludedthatthehearingofficer did not abuse her discretion by admitting into evidence the text messages at issue in this appeal. Specifically, the plaintiff claims that the text messages were not properly authenticated to prove that he was their author. We disagree.We begin by setting forth the relevant standard of reviewandapplicable law. ‘‘We reviewthe issuesraised by the plaintiffin accordance with the limited scope of judicialreviewaffordedbythe [UniformAdministrative Procedure Act (UAPA), General Statutes § 4-166 et seq.]4

. . . . Judicial review of an administrative agency decision requires a court to determine whether there is substantial evidence in the administrative record to support the agency’s findings of basic fact and whether the conclusions drawn from those facts

are reasonable.

. . . Our ultimate duty is to determine, in view of all of the evidence, whether the agency, in issuing its order, acted unreasonably, arbitrarily, illegally or in abuse of its discretion.’’ (Footnote added; internalquotationmarks omitted.)Family Garage, Inc.

v. Commissioner of Motor Vehicles, 130 Conn. App. 353, 357, 23 A.3d 752, cert. denied, 302 Conn. 931, 28 A.3d 345 (2011). ‘‘[T]he plaintiff bears the burden of demonstratingthatahearingofficer’s evidentiaryruling is arbitrary, illegal or an abuse of discretion.’’ (Internal quotation marks omitted.) Lucarelli v. Freedom of Information Commission, 135 Conn. App. 807, 817, 43 A.3d 237 (2012).
‘‘Anadministrativefindingissupportedbysubstantial evidence ifthe record affords asubstantial basis offact fromwhichthe factin issue canbe reasonablyinferred.

. . . The substantial evidence rule imposes an importantlimitation onthe power ofthe courts to overturn a decision of an administrative agency

. . . and

. . . provide[s] a more restrictive standard of review than standards embodying review ofweight ofthe evidence or clearly erroneous action.

. . . [I]t is something less than the weight of the evidence, and the possibility of drawing two inconsistent conclusions from the evidence does not prevent an administrative agency’s finding from being supported by substantial evidence.

. . . ‘‘[A]s to questions of law, [t]he court’s ultimate duty is only to decide whether, in light of the evidence, the [agency] has acted unreasonably, arbitrarily, illegally,

or in abuse of its discretion.

. . . Conclusions of law reached by the administrative agency must stand ifthe courtdeterminesthattheyresultedfromacorrectapplicationofthelawtothefactsfoundandcouldreasonably and logically follow from such facts.’’ (Internal quotation marks omitted). Family Garage, Inc. v. CommissionerofMotor Vehicles, supra, 130 Conn. App. 357–58. ‘‘Authentication is

. . . a necessary preliminary to the introduction of most writings in evidence

. . . .’’ (Internal quotation marks omitted.) Nash v. Stevens, 144 Conn. App. 1, 39, 71 A.3d 635, cert. denied, 310 Conn. 915, 76 A.3d 628 (2013). ‘‘The requirement of authenticationas aconditionprecedentto admissibility is satisfied by evidence sufficient to support a finding that the offered evidence is what its proponent claimsit to be.

. . . In general, a writing may be authenticated by a number ofmethods, including direct testimony or circumstantial evidence.

. . . Both courts and commentators have noted that the showing of authenticity is not on aparwiththe more technical evidentiaryrules that govern admissibility, such as hearsay exceptions, competency and privilege.

. . . Rather, there need only be a prima facie showing of authenticity to the court.

. . . Once a prima facie showing of authorship is made to the court, the evidence, as long as it is otherwise admissible, goes to the [finder offact], which ultimately will determine its authenticity.’’ (Citation omitted; internal quotation marks omitted.) Id., 38–39. ‘‘[T]hebarforauthenticationofevidenceisnotparticularly high.

. . . [T]he proponent need not rule out all possibilities inconsistent with authenticity, or

. . . prove beyond any doubt that the evidence is what it purports to be

. . . .’’ (Citation omitted; internal quotation marks omitted.) United States v. Vayner, 769 F.3d 125, 130 (2d Cir. 2014).5 In addition, ‘‘[a]n electronic document may

. . . be authenticated by traditional

means such as directtestimonyofthepurported author

or circumstantial evidence of ‘distinctive characteristics’ in the document that identify the author.’’ State v. Eleck, 130 Conn. App. 632, 640, 23A.3d 818 (2011), aff’d, 314 Conn. 123, 100 A.3d 817 (2014). Furthermore, this court need not consider whether the text messages were authenticated and admitted in accordancewiththe ConnecticutCode ofEvidence. Itis axiomatic that ‘‘administrative tribunals are not strictly bound by the rules of evidence

. . . . [T]hey may consider exhibits [that] would normally be incompetent in
ajudicialproceeding, so long as the evidence is reliable and probative.’’ (Internal quotation marks omitted.) F.M. v. Commissioner of Children & Families, 143 Conn. App. 454, 477, 72 A.3d 1095 (2013). According to General Statutes § 4-178, in a contested case before an agency, ‘‘[a]ny oral or documentary evidence may be received, but the agency shall, as a matter of policy, provide for the exclusion of irrelevant, immaterial or unduly repetitious evidence

. . . .’’ See also Regs., Conn. State Agencies § 17a-101k-8 (g). ‘‘Moreover, hearsay evidence is not prohibited in administrative proceedings

. . . . Hearsay testimony generally is admissible in administrative hearings as long as itis sufficientlytrustworthy.’’ (Citation omitted; internal quotation marks omitted.) F.M. v. Commissioner of Children & Families, supra, 143 Conn. App. 477.
On appeal, theplaintiffassertsthatthe textmessages admitted into evidence during the substantiation hearing were not properly authenticated.6 According to the plaintiff, the trial court’s focus on the chain of custody of the text message records and G.M.’s alleged lack of motivation to fabricate the allegations against theplaintiff was misplaced because the foregoing factors have no bearing on whether the plaintiff authored the text messages to G.M. Furthermore, the plaintiffclaims that the content of the text messages alone, without corroboration, was insufficient to prove that he authored them. The plaintiffalso claims that the multiplelayersofhearsaycontainedwithinthetextmessages rendered them untrustworthy.
After a careful review of the record, we agree with the court and conclude that the text messages were sufficiently authenticated to identify the plaintiff as their author. The court correctly found that there was
no evidence oftampering in the chain ofcustody ofthe text message records, which bolsters the reliability of the records. Furthermore, the court correctly found that there was no evidence indicating that G.M. fabricatedthe allegations againstthe plaintiff, which further buttresses the reliability of the records.
The plaintiff’s chief assertion is that the content of the text messages did not establish that he authored them. Although the plaintiffconcedes that, on the basis ofthe content ofthe text messages and the time period within which they were exchanged, he fell within the category of individuals who may have authored them, he claimsthatthe evidence failedtoprove affirmatively that he was their author. The plaintiffargues that there

wasnoevidencethattherewasanyinappropriatephysical contact between the plaintiff and G.M., or that the plaintiff had a cell phone account associated with the cell phone number from which G.M. received the text messages. The plaintiff claims that, without such corroborating evidence, the text messages, taken alone, did not sufficiently establish that he authored them. We disagree.
As we previously explained in this opinion, the bar for afinding ofauthenticityis not high. UnitedStates v. Vayner, supra, 769F.3d 130. Apartyprofferingevidence does nothave theburdento disprove allpossible inconsistencies with authenticity, or prove beyond all doubt thatthetextmessages arewhatthepartypurportsthem to be. Id. All that is required is a prima facie showing ofauthenticity. Nash v. Stevens, supra, 144 Conn. App. 39. This may be illustrated through circumstantial evidence drawn from the content of the text messages alone, without additional evidence. See State v. Eleck, supra, 130 Conn. App. 642–44 (noting that cases establishing authorship of messages based on their content focus onparticularlydistinctive identifying characteristics ofmessages and often, but not always, corroborating evidence). Here, the contents of the text messages established

a prima facie showing that the plaintiffauthored them. As the trial court correctly found, the text messages contained distinctive characteristics sufficient to authenticate the identity of the author as the plaintiff.The exhibit containing the text message records spanned forty two pages and included numerous, detailed conversations. Cf. State v. Eleck, supra, 130 Conn. App. 642 (contents of single electronic message vaguelyreferencinghistorybetweenpartiesinsufficient to prove authorship). Inthe text messages sentto G.M., the authorprovided the following information: he identified himself as a teacher at G.M.’s school; he noted detailed physical characteristics of G.M. and also complimented G.M. on her appearance at school on certain days; he repeatedly asked G.M. to delete the text messages and expressed concern about losing his job if a thirdparty discoveredthe textmessages; he referenced sending text messages to another female student at the school; he mentioned seeing G.M. at her high school’s junior prom and specifically stated that G.M. did not speak to him at the prom, a fact G.M. confirmed in a subsequent text message; he noted that G.M.’s sister oftentimes looked at him at school, a fact G.M. confirmed in a subsequent text message; he mentioned seeing G.M.’s mother at a parent teacher conference and noted similarities between G.M. and her mother; he asked G.M. whether she believed that a female student she knew disliked him as a result ofthe attention he gave to G.M.; he listed the names of a few female students at the school whom he considered attractive; he discussedinteractions he hadwithteachers he knew in the school; he mentioned seeing G.M. during lunch breaks at the school; he described having a ‘‘special’’ relationship with G.M. ‘‘since the beginning,’’ a statement G.M. agreed with in a subsequent text; he noted givingG.M. a‘‘highfive’’ atschool, afactG.M. confirmed in a subsequent text; and he mentioned observing at
onepointG.M. speakingwithanotherstudentatschool,

afact G.M. confirmed in a subsequent text. The foregoing details contained in the text messages provided the hearing officer with sufficient evidence to find that the plaintiff authored the text messages sent to G.M. The lack of corroborating evidence, such as evidence of other interactions between the plaintiff and G.M. or phone records linking the plaintiff to the cell phone number that sent the text messages to G.M., did not diminish the probative value of the text message records.
The plaintiff further claims that the text messages
were unreliable because they contained layers ofhearsayand,therefore,thehearingofficerabusedherdiscretionbyprimarilyrelyingonthemtofindthattheplaintiff had authoredthe text messages. We disagree. Evidence containing hearsay maybe admitted during administrative hearings so long as it is sufficiently trustworthy. F.M. v. Commissioner ofChildren & Families, supra, 143 Conn. App. 477. The record contains no evidence indicating thatthe text messages are untrustworthy. As

we previously mentioned, the chain of custody did not indicate any evidence of alterations to the text mes-sages, and there was no evidence indicating that G.M. had any motive to fabricate the allegations against the plaintiff. Therefore, the hearing officer did not abuse her discretion by admitting the exhibit containing the text messages because the mere fact that the text messages contained hearsay did not render them untrustworthy.
For the foregoing reasons, we agree with the court and conclude that the hearing officer had substantial evidence indicating that the plaintiff authored the text messages sent to G.M. Despite the fact that the text messages containedhearsay, the hearing officerdidnot act unreasonably, arbitrarily, illegally, or in abuse of her discretion in admitting into evidence the exhibit containing the text messages. The judgment is affirmed.
In this opinion the other judges concurred.

1 In accordance with our policy ofprotecting the privacy interests of the victims of sexual abuse, we decline to identify the victim or others through whomthevictim’sidentitymaybeascertained. SeeGeneralStatutes § 54-86e.

2 General Statutes § 17a-101k (a) provides in relevant part: ‘‘The Commissioner ofChildren and Families shall maintain a registry ofthe commissioner’s findings of abuse or neglect of children pursuant to section 17a-101g

. . . . The regulations

. . . shall provide for the use of the registry on a twenty-four-hour daily basis to prevent or discover abuse of children and the establishment of a hearing process for any appeal by a person of the commissioner’s determination that such person is responsible forthe abuse

or neglect of a child pursuant to subsection (b) of section 17a-101g. The information contained in the registry and any other information relative to child abuse, whereverlocated, shall be confidential, subjectto such statutes and regulations governing their use and access as shall conform to the requirements of federal law or regulations.

. . .’’ General Statutes § 17a-101g provides in relevant part: ‘‘(b)

. . . After an investigation into a report of abuse or neglect has been completed, the commissioner shall determine, based upon a standard ofreasonable cause, whether a child has been abused or neglected, as defined in section 46b120. If the commissioner determines that abuse or neglect has occurred, the commissioner shall also determine whether: (1) There is an identifiable person responsible for such abuse or neglect; and (2) such identifiable personposes ariskto the health, safety orwell-being ofchildren and should be recommended by the commissioner for placement on the child abuse andneglectregistry establishedpursuantto section 17a-101k. Ifthe commissioner has made the determinations in subdivisions (1) and (2) of this subsection, the commissioner shall issue notice of a recommended finding to the person suspected to be responsible for such abuse or neglect in accordance with section 17a-101k. ‘‘(c) Except as provided in subsection (d) of this section, no entry of the recommended finding shall be made on the child abuse or neglect registry andno information concerningthe finding shallbe disclosedbythe commissioner pursuant to a check of the child abuse or neglect registry

. . . until the exhaustionorwaiverofalladministrative appeals availabletotheperson suspected to be responsible for the abuse or neglect, as provided in section 17a-101k.

. . .’’

3 General Statutes § 4-183 (a) provides: ‘‘A person who has exhausted all administrative remedies available within the agency and who is aggrieved by a final decision may appeal to the Superior Court as provided in this section. The filing of a petition for reconsideration is not a prerequisite to the filing of such an appeal.’’

4 General Statutes § 4-183 (j) provides in relevant part: ‘‘The court shall not substitute its judgment for that of the agency as to the weight of the evidence on questions of fact. The court shall affirm the decision of the agency unless the court finds that substantial rights ofthe person appealing have been prejudiced because the administrative findings, inferences, conclusions, or decisions are: (1) In violation of constitutional or statutory provisions; (2) in excess of the statutory authority of the agency; (3) madeupon unlawful procedure; (4) affected by other error of law; (5) clearly

erroneous in view of the reliable, probative, and substantial evidence on the whole record; or (6) arbitrary or capricious or characterized by abuse of discretion or clearly unwarranted exercise of discretion.

. . .’’

5 Vayner concerns rule 901 of the Federal Rules of Evidence, which is similar § 9-1 ofthe Connecticut Code ofEvidence regarding the requirement of authentication.

6 In his appellate brief, in the context ofhis analysis ofthe authentication issue, the plaintiff broadly claims that a procedural due process violation occurred on the basis of his alleged failure to have a sufficient opportunity to conduct cross-examination regarding the foundation and origin of the text messages. The commissioner argues that, to the extent the plaintiff raises this claim, he inadequately briefed it. We conclude that his summary treatment of this claim is inadequate. See Practice Book § 67-4 (a) and (d). Thus, we agree with the commissioner and decline to review this claim. See Clelford v. Bristol, 150 Conn. App. 229, 233, 90 A.3d 998 (2014) (‘‘[i]t is well settledthat [w]e are not requiredto review claims that are inadequately briefed’’ [internal quotation marks omitted]).