Court Rulings

A Shelby County jury convicted Defendant, Christopher Bolden, of especially aggravated robbery, for which he received a sentence of twenty years' incarceration. On appeal, Defendant contends that: (1) the trial court erred in denying his motion to dismiss the indictment for lack of a speedy trial (2) the trial court erred in denying his motion for severance of his case from that of his co-defendant (3) the trial court erred in \curtailing [Defendant's] questions in jury selection\ (4) the trial court erred in denying Defendant's request to cross-examine the victim about \potential bias\ related to cases that the State dismissed against the victim while Defendant awaited trial (5) the trial court erred in admitting Defendant's prior conviction for robbery \without engaging in the required analysis\ (6) the trial court erred in allowing the State to ask questions about \an irrelevant and prejudicial rap music video\ (7) the trial court erred by refusing to fully bifurcate a charged count of convicted felon in possession of a firearm from all other counts and (8) the evidence was insufficient to support his conviction. Following a thorough review, we affirm Defendant's judgment of conviction.

An employer terminated an employee after she requested unpaid commissions pursuant to her contract. The employee sued her former employer claiming breach of contract, unjust enrichment, retaliatory discharge, and intentional misrepresentation. She also sought punitive damages. The jury found in the employee's favor on all claims and awarded damages for breach of contract, unjust enrichment, and retaliatory discharge as well as awarding punitive damages. The former employer sought post-trial relief, arguing the jury's verdicts were inconsistent and that the jury's punitive damages award was in error and excessive. The trial court concluded the verdicts were consistent but did reduce, while not eliminating, the punitive damages award. The former employer appeals, challenging the compensatory and punitive damage awards. We affirm.

The plaintiff sought to recover damages from the defendant school district for her alleged constructive discharge from employment as a teacher. The plaintiff had been employed by the defendant for approximately twenty-four years when she resigned from her position in August, 2019. On December 19, 2019, she filed an age discrimination complaint with the Commission on Human Rights and Opportunities (CHRO). There- after, the CHRO issued a release of jurisdiction over the complaint, and the plaintiff commenced the present action against the defendant, alleging a violation of the Connecticut Fair Employment Practices Act (§ 46a-51 et seq.), constructive discharge, and breach of contract. The plaintiff, who was seventy years old, claimed that she was forced to resign after the defendant created an intolerable work environment by marginalizing and unfairly criticizing her because it wanted to replace her with a younger teacher. The defendant filed a motion to strike the plaintiff's complaint on the grounds that it was untimely and failed to state a claim on which relief could be granted. The trial court granted the defendant's motion, and, thereafter, the plaintiff filed an amended complaint alleging only constructive discharge. In that complaint, the plaintiff added allegations related to a report issued by the defendant on June 10, 2019, in which it acknowledged that an assistant principal had copied certain portions of the plaintiff's prior evaluations into her 2016–2017 school year evaluation and recommended a review of adminis- trators' practices of referencing evaluations from prior years. The defen- dant filed a motion to strike, which the trial court granted, finding that the plaintiff's complaint to the CHRO was untimely pursuant to the 180 day limitation period set forth in the applicable statute ((Rev. to 2019) § 46a-82 (f)), because the plaintiff had failed to identify conduct relating to an intolerable working environment that had persisted to June 22, 2019, o