Justia Labor & Employment Law Opinion Summaries

Articles Posted in Connecticut Supreme Court
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The Supreme Court affirmed the judgment of the Appellate Court affirming the judgment of the Compensation Review Board finding that the City of Bridgeport was liable for the payment of Plaintiff's workers compensation benefits as his principal employer, holding that the City was in the "trade or business" of maintaining and repairing municipal buildings and facilities.The City hired Contractor do repair work on the roof of the City's transfer facility, and Contractor hired Subcontractor. Plaintiff, an employee of Subcontractor, was injured in the course and scope of his employment and sought workers' compensation benefits from the City, Contractor, and Subcontractor. The Workers' Compensation Commissioner concluded that, because Howie's Roofing was uninsured, the Second Injury Fund was required to pay Plaintiff benefits under Conn. Gen. Stat. 31-355. The Fund contested liability, arguing that the City was required to pay the benefits owed to Plaintiff as his principal employer. The Commissioner determined that the City was Plaintiff's principal employer and ordered the City to pay workers' compensation benefits. The Supreme Court affirmed, holding that roof repair was a part or process in the City's trade or business under Conn. Gen. Stat. 31-291. View "Barker v. All Roofs by Dominic" on Justia Law

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The Supreme Court affirmed the judgment of the Appellate Court concluding that a university police officer is not a member of a "local police department" entitled to indemnification under Conn. Gen. Stat. 53-39a, holding that the Appellate Court correctly interpreted the statute.Plaintiff, a member of a special police force for Eastern Connecticut State University, demanded reimbursement from the State for economic losses he allegedly incurred as a result of his federal criminal prosecution. In his complaint, Plaintiff argued that a university's special police force is a "local police department" for purposes of section 53-39a. The trial court rendered judgment in favor of Plaintiff. The Appellate Court reversed, holding that a university police officer is not a member of a local police department entitled to indemnification under section 53-39a. The Supreme Court affirmed, holding that the Appellate Court's reasoning was sound and its conclusion was correct. View "Praisner v. State" on Justia Law

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In this action for constructive discharge, the Supreme Court affirmed the judgment of the Appellate Court affirming the trial court's judgment granting Defendant's motion to strike, holding that Plaintiff's complaint failed as a matter of law to allege that Defendant created a work atmosphere so difficult or unpleasant that a reasonable person in Plaintiff's shoes would have felt compelled to resign.Plaintiff, an optician formerly employed by Defendant, brought this action alleging that Defendant required him to violate public policy and that, as a result, Plaintiff was compelled to resign. The trial court granted Defendant's motion to strike, relying on Brittell v. Department of Correction 7171 A.2d 1254 (Conn. 1998). The Appellate Court affirmed. The Supreme Court affirmed, holding that Plaintiff failed sufficiently to allege the second requirement of a constructive discharge claim in his complaint. View "Karagozian v. USV Optical, Inc." on Justia Law

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The Supreme Court affirmed the decision of the Compensation Review Board, which reversed the decision of the Workers' Compensation Commissioner denying benefits to Plaintiff pursuant to Conn. Gen. Stat. 7-433c(a), holding that the Board incorrectly determined that Plaintiff's heart disease claim was untimely.The Commissioner found that Plaintiff was neither diagnosed with heart disease nor filed a claim for that disease under section 7-433c until after he had retired. Therefore, the Commissioner concluded that Plaintiff's disease and resulting disability were not suffered while Plaintiff was employed by Defendant and that even if Plaintiff was developing heart disease while he was employed by Defendant that was not sufficient to make the claim compensable. The Board reversed, concluding that it was reasonable to infer that Plaintiff's heart disease was the sequela of his accepted claim under section 7-433c for hypertension. The Supreme Court affirmed, holding (1) Plaintiff's initial claim for hypertension met the requirements of section 7-433c, was timely, and was compensable; and (2) the Board reasonably concluded that Plaintiff's heart disease was the sequela of his hypertension, which was the injury at issue in his primary claim. View "Coughlin v. Stamford Fire Department" on Justia Law

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The Supreme Court affirmed the decision of the Compensation Review Board, which vacated the decision of the Workers' Compensation Commissioner dismissing Plaintiff's claim for benefits brought pursuant to Conn. Gen. Stat. 7-433c(a), holding that Plaintiff met the jurisdictional prerequisites of section 7-433c and that, on remand, the Commissioner shall determine whether Plaintiff's hypertension was a substantial factor in his subsequent development of heart disease.The Commissioner found that Plaintiff was not entitled to benefits for heart disease because he failed to file a notice of new claim within one year of his diagnosis. In making this finding, the Commissioner rejected Plaintiff's argument that his heart disease diagnosis was the sequela of his compensable claim for hypertension. The Board vacated the Commissioner's dismissal because the Commissioner did not present findings as to whether Plaintiff's heart disease was caused by his hypertension or constituted a new injury. The Supreme Court affirmed and remanded the case, holding (1) when a plaintiff has a compensable claim for hypertension under section 7-433c, the plaintiff may also be eligible for benefits for subsequent heart disease if his heart disease is causally related to his hypertension; and (2) Plaintiff was not required to file a notice of new claim in order to pursue benefits for his heart disease. View "Dickerson v. Stamford" on Justia Law

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In this action to recover damages for personal injuries resulting from an allegedly defective product the Supreme Court reversed the judgment of the trial court granting summary judgment in favor of Defendants, holding that the amendment to the statute of repose in Number 17-97 of the 2017 Public Acts (P.A. 17-97) retroactively applied to Plaintiff's claims.On appeal, Plaintiff argued that the statute of repose applied to her product liability claims is unconstitutional because it creates two classes of claimants - employees subject to a ten-year statute of repose and nonemployees not subject to the statute of repose if the claimant shows the product was within its useful safe life when the injury occurred. While Defendants' motions for summary judgment were pending the legislature enacted P.A. 17-97, which combined the two classes of claimants by removing the limitation provision applicable to employees. The trial court concluded that P.A. 17-97 was not retroactive and applied the ten-year statute of repose to bar Plaintiff's claims. The Supreme Court reversed, holding that the amendment to the statute of repose in P.A. 17-97 retroactively applied to Plaintiff's claims. The Court remanded to determine whether there is a genuine issue of material fact as to whether the injury occurred during the safe life of the product. View "King v. Volvo Excavators AB" on Justia Law

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In this case concerning the proper recipient of heart and hypertension benefits under Conn. Gen. Stat. 7-433c for permanent disability if such benefits vested and were payable during the claimant's lifetime but were not paid to the claimant before his death the Supreme Court reversed the decision of the Compensation Review Board concluding that the executrix of the decedent's estate was improperly was substituted as party claimant, holding that heart and hypertension benefits under § 7-433c may be paid to a claimant’s estate if such unpaid benefits matured before the claimant’s death.The Workers' Compensation Commissioner granted the motion to substitute the executrix as a party claimant. The Board concluded that the executrix was improperly substituted as party claimant because a claimant's estate cannot receive the claimant's vested but unpaid section 7-433c benefits. The Supreme Court disagreed, holding (1) neither Morgan v. East Haven, 546 A.2d 243 (Conn. 1988), nor any other legal authority barred the substitution to the extent that the executrix sought payment of matured benefits; but (2) because the record did not support the determination that the decedent's section 7-433c disability benefits matured before his death, this case must be remanded for further proceedings to decide the proper beneficiary of any benefits due. View "Brennan v. Waterbury" on Justia Law

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In this dispute between the Board of Education of the Town of New Milford (Board) and the New Milford Education Association (Union) the Supreme Court affirmed the judgment of the trial court denying the Board's application to vacate a grievance arbitration award and granting the Union's application to confirm the grievance arbitration award, holding that the arbitrator did not manifestly disregard the law and properly concluded that the Union's grievance was arbitrable.The Union, which represented the teachers employed by the Board, filed a grievance alleging that the Board had violated an agreement between the parties. The arbitrator decided the grievance in the Union's favor. The trial court denied the Board's application to vacate the grievance arbitration award and granted the Union's application to confirm the award. The Supreme Court affirmed, holding that the trial court (1) correctly denied the Board's application to vacate the grievance arbitration award on the grounds that the arbitrator manifestly disregarded the law by concluding that the doctrines of collateral estoppel and res judicata did not apply to bar the Union's grievance; and (2) the trial court properly concluded that the Union's grievance was arbitrable under the terms of the agreement. View "Board of Education of Town of New Milford v. New Milford Education Ass'n" on Justia Law

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The Supreme Court reversed the decision of the Compensation Review Board affirming the decision of the Workers' Compensation Commissioner concluding that Plaintiff was not an employee of Intervale Group, LLC for purposes of the Workers' Compensation Act, holding that Plaintiff qualified as Intervale's employee for purposes of the Act and, therefore, was eligible for concurrent compensation benefits pursuant to Conn. Gen. Stat. 31-310.Plaintiff was the sole member of Intervale, a single-member limited liability company. Plaintiff was employed part-time by the City of Stamford. After he was injured while working for the City, Plaintiff sought compensation based on the earnings that he received from both the City and Intervale, claiming that he was concurrently employed by Intervale. The City transferred the concurrent compensation obligation to the Second Injury Fund, which denied the claim for benefits on the ground that Plaintiff was not Intervale's employee. The Commissioner concluded that Plaintiff was not an employee of Intervale, and the Board affirmed. The Supreme Court reversed, holding that because Plaintiff provided services to Intervale and was subject to the hazards of Intervale's business, Plaintiff was Intervale's employee for purposes of the Act. View "Gould v. Stamford" on Justia Law

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In this workers’ compensation case, the Supreme Court held that Defendant-employer was collaterally estopped from challenging an employee’s eligibility for benefits under the Workers’ Compensation Act (state act), Conn. Gen. Stat. 31-275 et seq., because of an earlier decision by a United States Department of Labor administrative law judge (ALJ) awarding benefits to the employee under the federal Longshore and Harbor Workers’ Compensation Act (Longshore Act), 33 U.S.C. 901 et seq.The Supreme Court affirmed the decision of the Compensation Review Board (Board) reversing the decision of the Workers’ Compensation Commissioner dismissing the claims for benefits under the state act filed by Plaintiff, the executor of the decedent’s estate and the decedent’s widow. The Court held that the Board properly determined that the employer in this case was collaterally estopped from relitigating the issue of causation under the state act because the record of the Longshore Act proceedings indicated that the ALJ employed the substantial factor standard that governed the proceedings under the state act. View "Filosi v. Electric Boat Corp." on Justia Law