Justia Connecticut Supreme Court Opinion Summaries

Articles Posted in Labor & Employment Law

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When Employee received less compensation from Employer than that to which he believed he was entitled, Employee began to work for a competitor of Employer and to receive compensation for that work. Employer later terminated Employee’s employment and filed this action, alleging that Employee had breached the duty of loyalty to Employer by performing work on his own behalf during Employer’s workday and by accepting kickbacks from a subcontractor in connection with his work for Employer. The trial court held that Employee had violated his duty of loyalty to Employer. As part of its remedy, the trial court imposed a constructive trust on a bank account held jointly by Employee and his wife. The Supreme Court affirmed in part and reversed in part, holding (1) the trial court’s award of damages was supported by the evidence; (2) the trial court did not abuse its discretion in refusing to order additional monetary relief; and (3) the trial court’s imposition of a constructive trust on the joint bank account was not warranted on the evidence presented. View "Wall Systems, Inc. v. Pompa" on Justia Law

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A police union and the City of Norwalk were parties to a collective bargaining agreement (CBA) governing the terms and conditions of employment for certain city police officers. The CBA provided that disputes over its interpretation will be resolved through arbitration. The Board of Police Commissioners determined that Stephen Couture, a police sergeant employed by the Norwalk Police Department, had violated departmental rules and that his employment should be terminated. Couture ultimately initiated an arbitration proceeding with the State Board of Mediation and Arbitration, and a majority of the arbitration board found that Couture had been terminated for just cause. The trial court vacated the arbitration award on the ground that the City had disciplined Couture twice for the same misconduct in manifest disregard of the law. The Supreme Court reversed, holding that the arbitration board’s decision was not in manifest disregard of the law, and therefore, the trial court improperly vacated the award of the arbitration board. View "Norwalk Police Union, Local 1727 v. City of Norwalk" on Justia Law

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After he was terminated, Employee sued Employer, alleging, inter alia, disability discrimination. After a trial, the jury trial returned a verdict in favor of Employee and awarded him, inter alia, $500,000 in statutory punitive damages. Employer moved to set aside the award of punitive damages. The trial court granted the motion, determining that Conn. Gen. Stat. 46a-104 does not provide for an award of statutory punitive damages as a remedy for discriminatory practices under the Connecticut Fair Employment Practices Act. The Appellate Court affirmed. The Supreme Court affirmed, holding that section 46a-104 does not authorize punitive damages in employment discrimination cases. View "Tomick v. United Parcel Service, Inc." on Justia Law

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Plaintiff was employed as a police officer by Defendant when he was injured. The Workers’ Compensation Commissioner dismissed Plaintiff’s claim for Workers’ Compensation benefits, concluding that Plaintiff had not departed his “place of abode” for duty as a police officer at the time he sustained his injury, and therefore, the incident was not compensable. The Workers’ Compensation Board affirmed. The Supreme Court reversed, holding that Plaintiff was acting “in the course of his employment” at the time he was injured, and therefore, the Board erred in affirming the Commissioner’s decision to dismiss Plaintiff’s claim. View "Balloli v. New Haven Police Department" on Justia Law

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In 2006, Plaintiff’s decedent filed notices of claim with the Workers’ Compensation Commission. The Commission assigned the decedent’s claims to its asbestos docket for adjudication. After the decedent died, Plaintiff, his widow, filed a claim for dependent benefits that was joined with the original claims. The Connecticut Insurance Guaranty Association became a defendant in the proceedings. The Association was originally dismissed from the case for lack of exposure. The Commissioner later reinstated the Association as a party to the proceedings. The Workers’ Compensation Review Board affirmed. The Supreme Court affirmed the Board’s decision, holding that the Commissioner properly reinstated the Association as a party to the proceedings because the Commissioner’s broad case management authority permitted him to render a dismissal that was provisional, rather than final, in nature. View "Graham v. Olson Wood Associates, Inc." on Justia Law

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In 1996, Plaintiff was hired by Defendant, the New Haven Police Department, as a police officer. In 2011, Plaintiff suffered a myocardial infarction. Plaintiff later filed a claim for benefits under Conn. Gen. Stat. 7-433c(a) for hypertension and heart disease. The Workers’ Compensation Commissioner dismissed Plaintiff’s claim for benefits related to his hypertension as untimely but granted his claim for benefits related to his heart disease and myocardial infarction. The Workers’ Compensation Review Board affirmed. Defendant appealed, arguing that the Board improperly affirmed the Commissioner’s decision that Plaintiff’s hypertension and heart disease were separate diseases, each with its own limitation period for filing a claim for benefits. The Supreme Court affirmed, holding (1) the medical evidence supported the Board’s conclusion that Plaintiff’s hypertension and heart disease were separate medical conditions; and (2) the Board properly affirmed the Commissioner’s decision granting Plaintiff benefits pursuant to section 7-433c related to heart disease. View "Holston v. New Haven Police Department" on Justia Law

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James Doughty was injured during the course of his employment with Connecticut Reliable Welding, LLC (Reliable). Pacific Insurance Company, Ltd. (Pacific) had issued an insurance policy providing workers’ compensation coverage to Reliable and, therefore, paid Doughty workers’ compensation benefits. Pacific brought this action against Defendants - steel and construction companies - alleging negligence. Defendants moved to dismiss the complaint, arguing that that Pacific did not have standing to bring an action under either Conn. Gen. Stat. 31-293 or the common law doctrine of equitable subrogation. Pacific filed a motion to substitute Reliable as the party plaintiff. The trial court denied Pacific’s motion and granted Defendants’ motions to dismiss the complaint. The Supreme Court reversed, holding that a workers’ compensation insurer can maintain an equitable subrogation claim against third-party tortfeasors to recover benefits it has paid on behalf of an insured employer to an injured employee, and therefore, Pacific can properly assert an equitable subrogation claim. Remanded. View "Pacific Ins. Co., Ltd. v. Champion Steel, LLC" on Justia Law

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James Rock (the decedent) was employed by the University of Connecticut for more than thirty-five years before he died from a form of cancer that can be caused by occupational exposure to asbestos. The decedent never filed a notice of claim for workers’ compensation benefits. Plaintiff, the Estate of James Rock, filed a notice of claim for workers’ compensation benefits on behalf of the decedent. The Workers’ Compensation Commissioner dismissed Plaintiff’s claim for benefits for lack of standing. The Compensation Review Board upheld the dismissal but remanded the case to allow Plaintiff to advance a claim for burial expenses, lost wages the decedent sustained between his injury and his death, and medical expenses attributable to a compensable injury. The Supreme Court reversed in part, holding that an estate is not a legal entity capable of advancing a claim for any form of workers’ compensation benefits, and therefore, Plaintiff did not have standing to pursue any type of workers’ compensation benefits. View "Estate of Rock v. Univ. of Conn." on Justia Law

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After hiring Plaintiff, Defendant-employer amended its sales commission plan. At dispute in this case was a revised commission provision, which provided that Plaintiff’s commissions would not be paid unless Defendant had invoiced commissionable amount to the client prior to Plaintiff’s termination. After Plaintiff was terminated, he filed a wage statute claim alleging that the commission provision was contrary to public policy and a violation of Conn. Gen. Stat. 31-72. Plaintiff’s remaining two claims were stricken upon Defendant’s motion. After a trial, the court granted judgment in favor of Plaintiff, holding that the commission provision at issue was contrary to public policy. Both parties appealed. The Supreme Court affirmed in part and reversed in part, holding that the trial court (1) improperly determined that the commission provision violated public policy and constituted a violation of section 31-72; (2) erred in striking Plaintiff’s claim alleging breach of the implied covenant of good faith and fair dealing; and (3) did not err in striking Plaintiff’s claim alleging wrongful discharge. Remanded. View "Geysen v. Securitas Security Servs. USA, Inc." on Justia Law

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Plaintiff’s husband was employed by Defendant. Plaintiff discovered her husband’s dead body beneath a vehicle when bringing lunch to him at work. Plaintiff received survivors’ benefits under Defendant’s workers’ compensation insurance policy. Thereafter, Plaintiff sued Defendant for negligent infliction of bystander emotional distress. The trial court granted Defendant’s motion for summary judgment based on the language of the exclusivity provision of the Workers’ Compensation Act and the derivative nature of claims for bystander emotional distress. The Supreme Court affirmed, holding that because the Act applies to the parties in this case and there is a causal link between Plaintiff’s claim for bystander emotional distress and a compensable injury, Plaintiff’s claim was barred. View "Velecela v. All Habitat Servs., LLC" on Justia Law