Matter of Charter Communications, LLC v. New York State Div. of Human Rights

The plaintiff sought to recover damages for the alleged wrongful termination of her employment by the defendant, which she claimed was the result of pregnancy discrimination in violation of the Connecticut Fair Employ- ment Practices Act (§ 46a-51 et seq.). The defendant hired the plaintiff to work in its brand and creative strategy department. S, the only other employee in the department, was her supervisor. According to the plain- tiff, the two had a good working relationship through the end of her first month of employment, when the plaintiff informed S that she was pregnant. Thereafter, the relationship deteriorated. According to the plaintiff, S no longer invited her to collaborate on projects, became curt and unfriendly, and began to micromanage and criticize her work. S also started to document the plaintiff's alleged performance deficiencies. Less than five weeks after the plaintiff disclosed her pregnancy, S informed the plaintiff that her employment was being terminated for her poor performance. Following a trial to the jury, the jury returned a verdict in favor of the plaintiff on the issue of liability. Thereafter, the trial court denied the defendant's motion for judgment notwithstanding the verdict and awarded the plaintiff economic damages in addition to prejudgment interest, postjudgment interest, and attorney's fees. On appeal to this court, the defendant challenged only one element of the plaintiff's prima facie case, namely, whether she established that the termination of her employment occurred under circumstances that gave rise to an inference of discrimination. Held: 1. The trial court properly denied the defendant's motion for judgment notwithstanding the verdict: a. The plaintiff satisfied her initial burden of establishing a prima facie case of discrimination: there was sufficient evidence in the record from which a rational fact finder could have inferred that the termination of the plaintiff's employment was motivated by discriminatory bia