Wrongful Termination Cases

The named defendant, E, an employee of the plaintiff, the Department of Public Health, filed a complaint with the defendant Commission on Human Rights and Opportunities, alleging that the plaintiff retaliated against her for a whistleblower disclosure that she had made and that allegedly was protected by statute ((Rev. to 2017) § 4-61dd). E's job duties included reviewing the qualifications of individuals who are appointed to be a municipal director or acting director of health. The department had received an appointment letter from the then director of health of Hartford, requesting approval of W as Hartford's acting director of health. Both the letter and W's resume represented that W held a master's degree in public health, which is one of two alternative statutory ((Rev. to 2015) § 19a-200 (a)) prerequisites for the appointment to the position of municipal director of health. E reviewed the request, including W's resume, and she drafted a letter approving the appointment without first verifying that W actually possessed a master's degree in public health. The Commissioner of Public Health ultimately signed the approval letter. E subsequently learned that W did not possess a master's degree in public health, and, after she notified her supervisor, B, W was removed from the acting director position. Shortly thereafter, E again failed to verify the credentials of an individual who had been appointed to serve as another municipality's acting director of health. When B learned of the repeated error, E received a letter of reprimand. E subse- quently received another letter of reprimand and multiple, unsatisfactory performance appraisals, and was ultimately demoted. Pursuant to a collective bargaining agreement, E filed grievances challenging the fore- going, adverse personnel actions but did not raise a whistleblower retali- ation claim in connection with those grievances. All of the grievances were denied. E then filed the present whistleblower retaliation claim wit

Whether a unilateral amendment made pursuant to a change-of-terms provision violates the implied covenant of good faith and fair dealing and renders a contract illusory.