Hartford Police Dept. v. Commission on Human Rights & Opportunities
Case Details
- Judge(s)
- Robinson; D’Auria; Mullins; Ecker; Alexander
- Status — whether other courts must follow this ruling
- Published
- Procedural Posture — the stage the case had reached
- appeal
- State
- Connecticut
Related Laws
No specific laws identified for this ruling.
Claim Types
Outcome
The Connecticut Supreme Court reversed the Appellate Court and reinstated the human rights referee's finding that the Hartford Police Department discriminated against a Vietnamese officer based on ancestry when it terminated his employment. The court held that the officer established a prima facie case of discrimination through the transferred intent doctrine, and that the employer's stated reasons for termination were pretextual.
Excerpt
The defendant P filed a complaint with the named defendant, the Commis- sion on Human Rights and Opportunities, alleging that P's former employer, the plaintiff, the Hartford Police Department, had discrimi- nated against P on the basis of his ancestry. Upon graduating from the police academy, P, who is Vietnamese, began a probationary period of employment, which included a field training program and during which superior officers were required to complete daily observation reports evaluating his performance. P received a satisfactory rating upon com- pletion of the field training program and then continued to receive generally satisfactory daily evaluations from his superior officers, includ- ing K, who previously had been disciplined for making discriminatory and/or racist remarks to other individuals. Subsequently, on two separate occasions, K made certain remarks to P about his grammar and writing skills, criticizing P's accent, inquiring into P's ethnicity, nationality, edu- cational background, and whether the Hartford citizens with whom P interacted could understand him. When P indicated that he would file a grievance against K if he did not stop making such comments, K stated that P should ''watch what [he says] or [he] won't be around [for] long.'' K told other superior officers about his interactions with P and sent a memo to the commander of the police academy, calling P argumentative and confrontational. Thereafter, multiple officers began, for the first time, to label P as argumentative and confrontational in their daily observation reports. One officer wrote a memo noting that numerous daily observation reports were missing from P's file. In addition, days after K sent his memo to the commander, P was contacted about an incident that had occurred seven months earlier during field training, when P lost a piece of the hat to his uniform. When interviewed by the commander, P stated that, at the time he lost the hat piece, he had been ordered by his superi
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