In a recent decision, the Connecticut Appellate Court held that “supervisor” for hostile work environment discrimination claims brought under Connecticut law is the same as applied in similar federal claims brought pursuant to Title VII. The court’s decision in Tenisha O’Reggio v. Commission on Human Rights and Opportunities1 marks the first time Connecticut appellate courts have addressed the definition of “supervisor” under the Connecticut Fair Employment Practices Act (CFEPA).
The Path to the Appellate Court
The plaintiff worked as an adjudicator for the Connecticut Department of Labor. She filed a complaint with the Connecticut Commission on Human Rights and Opportunities (CHRO) alleging that the program service coordinator to whom she reported subjected her to a hostile work environment based on her race and color in violation of CFEPA.
At public hearing, the administrative law judge ruled in favor of the employer, concluding that although the program coordinator had created a hostile work environment, the employer acted promptly and reasonably to remedy the situation and was therefore not negligent.
In her appeal of the ALJ’s decision to the Connecticut Superior Court, the plaintiff argued that because the hostile work environment was created by her supervisor, the ALJ was required to impute liability to the employer. In response, the employer argued that even though the program coordinator was referred to as plaintiff’s supervisor, she did not meet that definition...
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