Town of Stratford v. American Federation of State, County and Municipal Employees, Council 15, Local 407, 315 Conn. 337

Summary

The Connecticut Supreme Court considered whether an arbitration award reinstating a Stratford police officer who had lied during an independent medical examination violated a clearly discernible public policy against intentional dishonesty by police officers. The court recognized such a public policy but held that the officer’s misconduct was not sufficiently egregious to require termination, given the substantial suspension and other conditions imposed by the arbitration panel. The court reversed the Appellate Court and directed that the trial court’s judgment upholding the arbitration award be affirmed.

Holdings

1. Connecticut has a public policy against intentional dishonesty by police officers in connection with their employment because integrity and trustworthiness are integral to the performance of official law-enforcement duties.
2. The arbitration award did not violate public policy because Loschiavo's dishonesty, although serious, was not so egregious that public policy required termination.
3. When a consensual arbitration award is challenged on a legitimate, colorable public-policy ground, the court conducts de novo review of whether enforcement would violate public policy while deferring appropriately to the arbitrator's factual conclusions and interpretation of the agreement.

Questions Presented

1. Whether Connecticut recognizes an explicit, well-defined, and dominant public policy against intentional dishonesty by police officers in connection with their employment.
2. Whether an arbitration award reinstating a police officer who intentionally lied during an independent medical examination violated that public policy by imposing less than termination.
3. What standard of review applies to a public-policy challenge to a consensual arbitration award.

Disposition

reversed_and_remanded