Justia Connecticut Supreme Court Opinion Summaries
Articles Posted in Labor & Employment Law
Dayner v. Archdiocese of Hartford
Plaintiff, employee, brought an action against Defendants, an archdiocese and a parish pastor, claiming that their refusal to renew her contract for employment as the principal of the parish school constituted, inter alia, wrongful termination in violation of public policy, breach of implied contract and breach of promissory estoppel. The trial court denied Defendants' motion to dismiss the action on the ground that adjudication of Plaintiff's claims called for impermissible judicial interference in the internal governance of the archdiocese with respect to its selection of religious leaders. At issue on appeal was whether the ministerial exception to judicial authority that precludes a court from adjudicating certain religious disputes required dismissal of the action. The Supreme Court first determined it had subject matter jurisdiction over the interlocutory appeal, and then reversed the trial court, holding that (1) in considering whether the ministerial exception is applicable in a particular case, a Connecticut state court must follow the Rweyemamu v. Cote standard; and (2) the ministerial exception applied to the various claims in the plaintiff's complaint. Remanded with direction to dismiss Plaintiff's complaint. View "Dayner v. Archdiocese of Hartford" on Justia Law
Franklin v. Superior Casting
Employee was diagnosed with silicosis, a condition caused by work with Employer, and filed a claim for workers' compensation benefits. During the course of Employee's employment, Employer's workers' compensation liability was covered by two insurers, first Liberty Mutual and, later, American Mutual. After Employee terminated his employment, American Mutual was declared insolvent. The Connecticut Guarantee Association subsequently became liable for certain American Mutual obligations. The workers' compensation commissioner held the association initially liable for payment of benefits as the last insurer on the risk. The workers' compensation review board affirmed. The association appealed, contending that deeming the association liable conflicted with the requirement under the Connecticut Insurance Guaranty Association Act that other insurance policies covering the same claim must be exhausted before recovery is permitted from the association. The Supreme Court affirmed, concluding that holding the association liable for an insolvent insurer's obligation as the last insurer on the risk does not conflict with the Guaranty Act. View "Franklin v. Superior Casting" on Justia Law
Singhaviroj v. Board of Education of the Town of Fairfield, et al.
Plaintiff sued defendants alleging violations of 42 U.S.C. 1983 and General Statutes 7-465 when defendants terminated plaintiff from his employment as a senior field engineer in defendants' information technology department after it had determined that he was responsible for disruptions in its computer network. At issue was whether the trial court abused its discretion in awarding defendants a portion of defendants' attorney's fees that it incurred in defending against plaintiff's action. The court held that the trial court acted well within its discretion in awarding attorney's fees where plaintiff continued to litigate his claims against defendants after it became clear that those claims were groundless.
Nyenhuis v. Metropolitan District Commission
On April 19, 2006, Plaintiff Gabrielle Nyenhuis, in the course of her employment as a uniformed police officer of Defendant Metropolitan District Commission (District), had an altercation with a member of the public. The following day, in response to a citizen complaint filed against her, the District placed Plaintiff on administrative duty. An internal investigation was launched, and in June, the West Hartford Police Department arrested Plaintiff and charged her with third degree assault. She would later be acquitted on the charge. The District reinstated Plaintiff to active duty. In November, 2007, Plaintiff initiated two complaints against the District pursuant to its grievance procedure, seeking accrued vacation and lost overtime stemming from the time she was placed on administrative duty until her reinstatement. While the grievances were pending, Plaintiff filed suit in the circuit court seeking indemnification for, among other things, the same vacation time and lost overtime. The court awarded Plaintiff damages and the District appealed. The Supreme Court affirmed the lower courtâs award of damages, but disagreed with the courtâs method of calculating them. The Supreme Court remanded the case back to the trial court for a rehearing on the issue of damages.
Posted in:
Connecticut Supreme Court, Labor & Employment Law
Motzer v. Haberli
Plaintiff Randall Motzer worked for Defendants Edward Haberli and E. Haberli Electric, LLC as an electricianâs apprentice. In June, 2004, he was working on a job site to help install electrical wiring through the ground floor of an apartment complex. The task required two people to complete. Bryan Papillo, the other worker, drilled holes through the floor above and fed wires to Plaintiff working below. In one instance, Plaintiff put his fingers through the hole to retrieve the wires and heard Papillo yell something just as a drill bit came down on Plaintiffâs finger. Plaintiff had to have part of his finger removed. As a result of this injury, Plaintiff received workersâ compensation benefits. Notwithstanding the benefits, Plaintiff filed a two count complaint against Defendants, alleging among other things, Defendants engaged in âserious and willful misconductâ and that conduct lead to Plaintiffâs injury. Defendants denied responsibility and raised five special defenses. A jury trial on the matter began in March, 2009. At the close of the case, Defendants moved for a directed verdict alleging Plaintiff failed to prove Defendants were the cause of Plaintiffâs injury. The trial court rendered judgment for Defendants. On review, the Supreme Court found that the record was sufficient to support the trial courtâs grant of a directed verdict to Defendants. The Supreme Court affirmed the judgment of the trial court.