Nilda Martinez, a Hispanic woman born in Puerto Rico and employed as a clerk typist at the Connecticut State Library, sued her employer alleging discrimination, retaliation, and hostile work environment based on race, ethnicity, and national origin under Title VII, as well as similar claims under the ADA due to her chronic asthma and under the Connecticut Fair Employment Practices Act, plus a claim for intentional infliction of emotional distress. The court granted the State Library's motion for summary judgment and dismissed all claims. It reasoned that Martinez had not shown she experienced an adverse employment action tied to her protected characteristics, that the nine alleged derogatory comments were insufficient to establish a severe or pervasive hostile environment, that the employer had offered a reasonable accommodation for her asthma by permitting a space heater, and that sovereign immunity barred the emotional distress claim against the state entity.
In this case arising from a multi-vehicle highway accident in Connecticut, plaintiffs Iosif and Marianna Ghimbasan sued truck driver Jeffrey Rice and his employer S & H Express for injuries and loss of consortium, bringing claims including statutory recklessness under Conn. Gen. Stat. § 14-295 and reckless entrustment/hiring against the employer. The court ruled on the defendants' motion to dismiss several counts under Fed. R. Civ. P. 12(b)(6). It denied dismissal of the statutory recklessness claim against Rice and the related consortium claim, but granted dismissal of the reckless entrustment claims against S & H Express and associated consortium claims. The core reasoning was that Connecticut does not recognize a cause of action for negligent or reckless entrustment of a motor vehicle, and loss of consortium claims are derivative and thus cannot stand without a viable underlying claim.
In Duncan v. Astrue, a pro se plaintiff sought judicial review under 42 U.S.C. §§ 405(g) and 1383(c)(3) of the Social Security Commissioner's denial of his applications for disability insurance benefits and supplemental security income, alleging errors in the evaluation of his impairments including mental retardation and other physical and mental conditions. The magistrate judge recommended granting the plaintiff's motion to reverse, but the district court sustained the Commissioner's objection after reviewing overlooked evidence in the record. The court denied the plaintiff's motion, granted the Commissioner's motion to affirm, and upheld the ALJ's determination that the plaintiff was not disabled. It applied the substantial evidence standard, finding the ALJ's five-step sequential evaluation—including steps on severe impairments, listed impairments, residual functional capacity for light work, and availability of other jobs—adequately supported by medical reports and other evidence despite contrary findings also being possible.
This case involves plaintiff Debra Odom, who has a brain injury, suing Waterford police officer Gilbert Maffeo, Police Chief Murray Pendleton, and the Town of Waterford over Maffeo's use of a Taser during a 2006 traffic stop for speeding and lane changes. Odom brought multiple claims including negligence, assault and battery, false imprisonment, negligent infliction of emotional distress, and violations of 42 U.S.C. § 1983 against the defendants, along with indemnification claims against the town. The court denied Maffeo's motion for summary judgment in full, finding disputed facts about whether he properly identified himself, whether Odom's disability affected her compliance, and whether the taser use was justified under Connecticut law. It granted Pendleton and Waterford's motion in part by dismissing the § 1983 and negligent supervision claims against them but denied it in part by allowing the indemnification claims for Maffeo's alleged torts to proceed to trial.
The case involved a dispute between the New Britain Board of Education and the New Britain Federation of Teachers over class size limits for special education classes specified in their collective bargaining agreement. The Board sought declarations and injunctions to invalidate these limits under the IDEA, related federal and state laws, and the Equal Protection Clause, claiming they conflicted with requirements for individualized education plans. After a bench trial, the court ruled in favor of the Union, finding no evidence that the class size provisions prevented compliance with students' IEPs or federal law, and that the provisions were rationally related to legitimate educational purposes without violating equal protection. The court denied all requested relief and directed the parties to arbitration as per the agreement.
The case involved a mother suing a Connecticut town, school board, superintendent, principal, and two teachers on behalf of her biracial son, alleging under 42 U.S.C. § 1983 that school officials failed to protect the child from peer racial harassment and committed specific discriminatory acts, including directing him to use a brown crayon for a self-portrait and physically grabbing him. After an earlier summary judgment ruling and remand from the Second Circuit on qualified immunity, the district court reconsidered whether the defendants were shielded from the equal protection and substantive due process claims in Counts One, Four, and Seven. The court held that the officials were not entitled to qualified immunity on the equal protection claims because the right to a racially nondiscriminatory school environment was clearly established at the time, but they were entitled to qualified immunity on the due process claims because no precedent clearly established that the crayon or grabbing incidents violated the child's rights without evidence of significant injury. As a result, the substantive due process claims were dismissed and the equal protection claims were allowed to proceed to trial.
