Justia Connecticut Supreme Court Opinion Summaries

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

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

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

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

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

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

Defendant served as the general contractor for the construction of a gas fired power plant and implemented a contractor controlled insurance program (CCIP) to centralize the purchasing of workers’ compensation insurance for the project. Plaintiffs, employees of Defendant’s subcontractors, were injured at an explosion that occurred at the power plant construction site. Plaintiffs received workers’ compensation benefits under the CCIP. Plaintiffs subsequently brought this action against Defendant under Conn. Gen. Stat. 31-293(a), asserting negligence and strict liability claims. The trial court granted summary judgment in favor of Defendant, concluding that Defendant “paid” workers’ compensation benefits to Plaintiffs, thus entitling it to “principal employer” immunity. The Supreme Court affirmed, holding (1) the trial court erred in interpreting the term “paid compensation benefits” in section 31-291; but (2) even under the proper construction of section 31-291, no genuine issue of material fact exists as to whether Defendant paid compensation benefits to Plaintiffs. View "Gonzalez v. O. & G. Indus., Inc." on Justia Law

Brenda Puryear filed a complaint with the Commission on Human Rights and Opportunities on behalf of her minor daughter, Sarah, alleging that Echo Hose Ambulance and the city of Shelton had discriminated and retaliated against Sarah on the basis of her race and color in violation of the Connecticut Fair Employment Practices Act (CFEPA) and Title VII of the Civil Rights Act. The Commission’s human rights referee struck the complaint on the ground that Sarah was not an employee under the “remuneration test” used to resolve similar federal causes of action. The trial court dismissed the Commission’s appeal, concluding that the referee properly applied the remuneration test. The Appellate Court affirmed. The Commission appealed, arguing that the Appellate Court erred in applying the federal remuneration test rather than Connecticut’s common-law “right to control” test to determine whether an unpaid volunteer is an “employee” under the CFEPA. The Supreme Court affirmed, holding that the Appellate Court did not err in concluding that the remuneration test is the appropriate test for determining whether a volunteer is an employee under CFEPA. View "Commission on Human Rights & Opportunities v. Echo Hose Ambulance" on Justia Law

Plaintiff allegedly suffered heart problems and psychological injuries during the course of his employment with Defendant, FedEx. The Workers’ Compensation Commissioner found that Plaintiff’s physical and psychological injuries were compensable and awarded him total incapacity benefits covering a period of forty-seven weeks. The Workers’ Compensation Review Board upheld the Commissioner’s findings and award. The Supreme Court affirmed, holding (1) the Board properly upheld the Commissioner’s determination that both Plaintiff’s physical and psychological injuries were compensable under the Workers’ Compensation Act; and (2) the Commissioner’s award was not excessive. View "Hart v. Federal Express Corp." on Justia Law

In 2008, the Department of Labor determined that that certain individuals who provided services for Standard Oil of Connecticut, Inc. (Plaintiff) were misclassified as independent contractors rather than as employees and that Plaintiff owed $41,501 in unemployment contribution taxes due to this misclassification. An appeals referee affirmed. The Employment Security Appeals Division, Board of Review, upheld the decision of the appeals referee. Plaintiff appealed, and a judge trial referee, exercising the powers of the superior court, dismissed the appeal. The Supreme Court reversed, holding that the trial court improperly determined that the individuals at issue were Plaintiff’s employees under the test set forth in the Connecticut Unemployment Compensation Act. View "Standard Oil of Conn., Inc. v. Adm’r, Unemployment Comp. Act" on Justia Law