Court Rulings

The plaintiff, whose marriage to the defendant previously had been dis- solved, appealed to this court from the judgment of the trial court modifying the defendant's alimony obligation. The parties' separation agreement, which was incorporated into the judgment of dissolution, required the defendant to make weekly alimony payments of $2769.23 to the plaintiff, an amount that was nonmodifiable downward unless the defendant earned less than $350,000 in annual adjusted gross earnings. Adjusted gross earnings was defined in the separation agreement, in part, as gross business receipts less business expenses. The defendant claimed that a substantial decrease in his annual income from his dental practice as a result of the COVID-19 pandemic constituted a change in circumstances that warranted a reduction in his alimony payments. The trial court heard expert testimony that the parties presented from accountants about the defendant's financial circumstances and his receipt of $159,000 in loans and grants the federal government distrib- uted in 2020 to businesses nationwide to help offset their loss of income during the COVID-19 pandemic. Both parties' accountants believed that the federal government would forgive the full amount of the loans. The plaintiff's accountant, T, determined that the defendant would not incur any federal income tax obligation due to the government's forgiveness of the loans and that the defendant would benefit from the deduction of payroll expenses on his corporate tax return. The defendant's accoun- tant, L, determined that the defendant had adjusted gross earnings of $240,123 in 2020, which did not include the funds received from the federal government, and that the proceeds of the loans would not reduce the defendant's expenses or be considered income or forgiveness of debt. The court concluded that the defendant had established a change in circumstances on the basis of L's determination that the defendant had adjusted gross earnings of $240,123

The plaintiff, a director of member services at the defendant C Co., sought to recover damages from various defendants for alleged gender discrimi- nation and retaliation in violation of a provision (§ 46a-60) of the Con- necticut Fair Employment Practices Act. A few years after the plaintiff was hired, several employees in her department resigned while she was the director, and a few of those employees expressed displeasure with working for her and voiced complaints about her during exit interviews. In response, the defendant D, the executive director of C Co., instructed B, the director of human resources of C Co., to conduct an investigation into the allegations, which resulted in the termination of the plaintiff's employment. The plaintiff then commenced an action against C Co. and a related entity and a separate action against D, B and the defendant T, the deputy director of C Co., with whom the plaintiff did not get along. The two actions were consolidated for the purposes of discovery, pretrial pleadings and trial. Subsequently, the defendants filed a motion for summary judgment in each case, arguing that there were no genuine issues of material fact that would permit an inference of gender discrimi- nation or, in the alternative, that her termination was a pretext for gender discrimination. The trial court granted the defendants' motion, and the plaintiff appealed to this court. Held that the trial court properly granted the defendants' motion for summary judgment in each case, as no reasonable jury could have concluded that the plaintiff's termination was motivated in whole or in part by gender discrimination: the plaintiff did not demonstrate the existence of a genuine issue of material fact as to whether the defendants' legitimate, nondiscriminatory justification for her discharge, namely, repeated charges of mismanagement of employees and failure to respect authority as detailed in the report of the investigation, was a pretext for unlawful discriminatio