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EMPLOYMENT LAW: Hostile environment claim for gender reinstated, not religion or race

EMPLOYMENT LAW: Hostile Environment Claim For Gender Reinstated, Not Religion Or Race

Because the defendant understood the nature of the plaintiff’s sexual harassment claim, the failure to expressly plead the pertinent Connecticut General Statute was not fatal to the claim and a genuine issue of material fact existed as to whether plaintiff was subjected to a hostile work environment based on sex.

The plaintiff, a black female born in the U.S. Virgin Islands who practices the Rastafarian religion brought this action under the Connecticut fair employment processes act alleging that AutoZone, Inc., engaged in disability discrimination and sexual harassment and unlawfully terminated her employment based on national origin, religion and race. The trial court grants summary judgment for the defendant on all claims. The appellate court affirms. The Supreme Court reverses on the sexual harassment complaint but otherwise affirms.

The Supreme Court states that there was ample evidence that the store manager treated the plaintiff in a despicable manner for her perceived national origin, religion, or race. However, there was no evidence of a causal connection between the discriminatory animus and the plaintiff’s termination for not following a loss prevention policy arising from a computerized report and attorney recommendation.  Absent any affirmative evidence of that causal connection, no inference of the defendant’s discriminatory intent could be made. The trial court and Appellate Court nonetheless erred in part in disallowing a sexual harassment claim on the grounds that the defendant was not notice of its statutory basis.

The defendant clearly understood that the allegations were intended to raise a hostile work environment claim regardless of whether the statute was specifically cited.

Feliciano v. Autozone, Inc., SC 19200 (March 31, 2015)

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