Summary
This Connecticut Appellate Court opinion affirms the trial court's grant of summary judgment in favor of a former police commissioner in an employment retaliation lawsuit brought by a state trooper. The court held that the plaintiff failed to establish a prima facie case of retaliation because he could not demonstrate a causal connection between his protected activity—filing a sexual harassment report—and his subsequent transfer, as the defendant lacked knowledge of the report at the time of the alleged retaliatory actions. Consequently, the appellate court found no genuine issue of material fact existed to support the plaintiff's claim under the state's Fair Employment Practices Act.
Topics
Practice areas
Questions Presented
- Whether the plaintiff established a prima facie case of retaliation under General Statutes § 46a‑60(b)(4).
Holdings
- The trial court properly granted summary judgment because the plaintiff failed to establish a factual basis connecting the defendant to the alleged retaliatory transfer; therefore, no genuine issue of material fact existed as to a prima facie retaliation claim.
Key quotations
“There is a lack of evidence of a temporal or logical connection between the plaintiff’s protected activity and the adverse employment action.” (at 10)
Factual background
Timothy Begley, a Connecticut State Police trooper, reported in 2016 that Detective Steven Citta had behaved sexually inappropriately. Citta was removed, and three years later Begley was transferred out of the intelligence center. Begley alleged the transfer was retaliatory, but the defendant did not see the report until his deposition and had no direct involvement in the transfer.
Procedural history
The plaintiff, a state trooper, filed a retaliation claim alleging that his 2016 report of a fellow officer's sexual harassment led to his 2019 transfer. The trial court granted summary judgment to the defendant, finding no genuine issue of material fact. The plaintiff appealed.