Justia Connecticut Supreme Court Opinion Summaries

Articles Posted in Labor & Employment Law
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The case involves a group of former firefighters who retired from the city of Meriden and claimed damages from the city and the Meriden Municipal Pension Board for alleged breach of a collective bargaining agreement. The plaintiffs, who retired in 2015, claimed that they should have received an increase in their pension benefits based on a 2% wage increase that was awarded retroactively in an arbitration process after the plaintiffs had retired. The trial court ruled in favor of the plaintiffs, holding that the defendants had breached the collective bargaining agreement by failing to recalculate the plaintiffs' pension benefits based on the retroactive wage increase.On appeal, the Connecticut Supreme Court reversed the trial court's decision. The Supreme Court held that the defendants did not breach the collective bargaining agreement. This conclusion was based on the fact that the pension plan did not allow for the recalculation of pension benefits for retirees who voluntarily retired before the issuance of the arbitration award. The court noted that the pension plan only allowed for a retroactive adjustment of pension benefits for those who were forced to retire due to reaching the mandatory retirement age of 65. The court also held that the trial court did not lack subject matter jurisdiction to hear the case, rejecting the defendants' claim that the plaintiffs failed to exhaust their administrative remedies before filing the lawsuit. View "Stiegler v. Meriden" on Justia Law

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The Supreme Court affirmed the judgment of the appellate court determining that the State Board of Labor Relations did not act unreasonably, illegally, arbitrarily, or in abuse of its discretion when it applied the clear and unmistakable waiver standard to a union's claim that the town's unilateral change to its pension plan constituted a refusal to bargain collectively in good faith, holding that there was no error.The Town of Middlebury appealed the labor board's determination that the Town violated the Municipal Employee Relations act (MERA), Mass. Gen. Stat. 7-467 et seq., by unilaterally changing the Town's practice of including extra pay duty in calculating pension benefits for members of the Fraternal Order of Police, Middlebury Lodge No. 34. The appellate court concluded that the labor board did not abuse its discretion or act unreasonably, illegally, or arbitrarily when it declined to apply the "contract coverage" standard adopted by the National Labor Relations Board (NLRB) in 2019. The Supreme Court affirmed, holding that it was proper for the appellate court to apply the clear and unmistakable waiver standard, rather than the contract coverage standard, in determining when whether the union had waived its statutory right to bargain collective regarding the manner in which the Town calculated its members' pension benefits. View "Middlebury v. Fraternal Order of Police, Middlebury Lodge No. 34" on Justia Law

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The Supreme Court affirmed the judgment of the trial court denying Plaintiff's application to vacate an arbitration award rendered in favor of Defendant and granting Defendant's motion to confirm the award, holding that Plaintiff failed to satisfy any of the legal standards required for reversal of the trial court's judgment.Defendant filed an arbitration complaint asserting claims of breach of contact, breach of fiduciary duty, and common-law fraud. The arbitrator issued an award in favor of Defendant. Thereafter, Plaintiff filed an application to vacate the award. The trial court denied the application to vacate and granted Defendant's motion to confirm the award. The Supreme Court affirmed, holding (1) the arbitrator gave Plaintiff the full and fair hearing to which he was entitled under governing law, public policy, and the parties' arbitration agreement; and (2) the arbitrator properly applied the fugitive disentitlement doctrine to prevent Plaintiff from asserting counterclaims or defenses, contesting the allegations, and viewing the evidence against him. View "Ahmed v. Oak Management Corp." on Justia Law

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The Supreme Court affirmed the judgment of the appellate court upholding the trial court's denial of Defendant's motion for remittitur in this wrongful termination action, holding that the appellate court did not err in affirming the judgment of the trial court denying Defendant's motion for remittitur.Plaintiff brought this action for wrongful termination in violation of public policy stemming from his termination from employment as a truck driver after he raised complaints to Defendant regarding the safety of Defendant's vehicles. The jury returned a verdict for Plaintiff and awarded him damages for lost wages. Thereafter, Defendant filed several postverdict motions, including his motion for remittitur seeking to reduce the damages award to zero dollars. The trial court denied the motions. Plaintiff appealed, and Defendant cross-appealed, claiming that the trial abused its discretion in failing to set aside the jury's award. The appellate court affirmed. The Supreme Court affirmed, holding that there was no error in the damages award. View "Roach v. Transwaste, Inc." on Justia Law

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The Supreme Court reversed the judgment of the appellate court concluding that there was not substantial record evidence to support the determination of the presiding human rights referee's determination of intentional discrimination in this action challenging an employment termination decision, holding that the appellate court erred.The referee determined that the Hartford Police Department had discriminated against Hoa Phan, a probationary police officer on the basis of his Vietnamese and Asian ancestry by terminating his employment. The trial court affirmed. The appellate court reversed, ruling that the trial court erred in finding that substantial evidence supported the referee's finding of intentional discrimination. The Supreme Court reversed, holding (1) the referee correctly determined that Phan had established his prima facie case; and (2) the appellate court's alternative holding that substantial evidence did not support the referee's finding of intentional discrimination was erroneous. View "Hartford Police Dep't v. Commission on Human Rights & Opportunities" on Justia Law

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The Supreme Court reversed the judgment of the appellate court affirming the decision of the Compensation Review Board upholding the finding and award of the Workers' Compensation Commissioner for the Second Districting ordering the town of Waterford to accept as compensable Plaintiff's claim for heart disease benefits pursuant to Conn. Gen. Stat. 7-433c, holding that the appellate court erred.In concluding that Plaintiff was entitled to benefits the Commissioner determined that section 7-433c does not define the phrase "uniformed member of a paid municipal fire department." The appellate court affirmed. On appeal, the town argued that the appellate court erred in determining that the definition of "member" in Conn. Gen. Stat. 7-425(5) does not govern whether the plaintiff was a uniformed member of a paid municipal fire department for purposes of section 7-433c. The appellate court affirmed. The Supreme Court reversed, holding that the definition of "member" in section 7-425(5) governs eligibility for benefits under section 7-433c. View "Clark v. Waterford, Cohanzie Fire Dep't" on Justia Law

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In these actions to recover underinsured motorist benefits allegedly due under certain automobile insurance coverage provided by the State pursuant to a collective bargaining agreement the Supreme Court held that the appellate court incorrectly concluded that the trial court should have reduced one appellant's award by the sums received in settlement of a claim under Connecticut's Dram Shop Act, Conn. Gen. Stat. 30-102.The trial court found for Appellants on liability but awarded only a fraction of the damages sought, due in part to the court's rejection of Appellants' PTSD claim. The appellate court reversed in part, concluding that the trial court's failure to reduce Appellants' damages by their dram shop recovery violated the common-law rule against double recovery. The Supreme Court reversed in part, holding that the appellate court (1) properly affirmed the trial court's conclusion that Appellants were not entitled to recover underinsured motorist benefits for alleged PTSD; and (2) improperly reversed the judgments insofar as the trial court determined that the State was not entitled to a reduction in the awards for sums received by Appellants in settlement of a dram shop claim. View "Menard v. State" on Justia Law

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The Supreme Court reversed the decision of the appellate court affirming the order of the superior court granting Defendant's motion for summary judgment as to the first count of Plaintiff's complaint in this action to recover damages for the allegedly wrongful discharge of Plaintiff, holding that summary judgment was improper.Defendant, a helicopter flight training school, hired Plaintiff as a flight instructor. When Plaintiff refused to share fees that he expected to receive as a Federal Aviation Administration certified pilot examiner Defendant terminated his employment. Plaintiff brought this action alleging wrongful discharge in violation of the public policy embodied in Conn. Gen. Stat. 31-73(b). The Supreme Court held that the appellate court improperly upheld the trial court's summary judgment for Defendant because genuine material questions of fact remained. View "Dunn v. Northeast Helicopters Flight Services, LLC" on Justia Law

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The Supreme Court reversed the decision of the appellate court reversing the judgment of the trial court finding that Defendant had discriminated against Plaintiff during the course of her employment by failing to provide reasonable accommodations for her disability, in violation of the Connecticut Fair Employment Practices Act, Conn. Gen. Stat. 46a-60(b)(1), and had unlawfully retaliated against her, holding that the trial court did not err.In reversing the judgment of the trial court, the appellate court concluded that the trial court improperly admitted into evidence written settlement communications, in violation of Conn. Code Evid. 4-8 and that the error was prejudicial. The Supreme Court reversed, holding (1) the trial court did not abuse its discretion in admitting the written communications into evidence; and (2) the other evidentiary errors identified by the appellate court were harmless. View "Kovachich v. Dep't of Mental Health & Addiction Services" on Justia Law

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The Supreme Court affirmed the judgment of the appellate court upholding the trial court's determination affirming the decision of the Board of Review of The Employment Security Appeals Division that tattoo services are part of the usual course of business of a body art and piercing business for purposes of the statutory ABC test used to determined whether an individual is an employee for purposes of the Unemployment Compensation Act, Conn. Gen. Stat. 31-222 et seq., holding that there was no error.Plaintiff, a business that provides body piercing and body art services, argued on appeal that the Board acted unreasonably and arbitrarily in holding it liable for unpaid unemployment compensation contributions after concluding that the offering of tattoo services was within Plaintiff's usual course of business. The Supreme Court affirmed, holding that substantial evidence existed to support the Board's determination that tattoo services were within Plaintiff's "usual course of business" for purposes of part B of the ABC test. See Conn. Gen. Stat. 31-222(a)(1)(B)(ii)(II). View "Vogue v. Administrator, Unemployment Compensation Act" on Justia Law