Recently, a Connecticut Federal Court ruled that a transgender discrimination claim based on a failure to hire can proceed under both Title VII and Connecticut’s counterpart, the Connecticut Fair Employment Practices Act (“CFEPA”). Notably, during the pendency of the case, Connecticut passed a law prohibiting discrimination on the basis of gender identity.
The Plaintiff alleged that she was nearly hired as an on-call orthopedic surgeon at the Hospital of Central Connecticut, and relied on the impending finalization of her hiring, but that the hospital declined to hire her because she disclosed her identity as a transgender woman who would begin working after transitioning to presenting as female.
The hospital moved for summary judgment on several grounds, including that Title VII (and the CFEPA at the time of the alleged discrimination) does not prohibit employment discrimination on the basis of transgender identity.
The District Court denied summary judgment. In so doing, it read Title VII’s prohibition of discrimination “because of . . . sex” to include transgender discrimination. Examining the plain language of the statute, and in light of prior Supreme Court precedent acknowledging gender-stereotype discrimination as discrimination “because of sex,” Judge Stefan Underhill concluded that discrimination on the basis of transgender identity is cognizable under Title VII.
The United States District Court for the District of Connecticut recently granted the summary judgment motion that Ryan & Ryan, LLC filed on behalf of its client, a machine and metal component company in Milford, Connecticut.
In the lawsuit, the Plaintiff alleged that she was subject to discrimination based on her disability, that her employer refused to provide a reasonable accommodation for her disability (wrist and knee injuries), and that she was retaliated against on account of her filing a worker’s compensation claim.
Ryan & Ryan, LLC conducted fact discovery and marshaled support for the defense theories that (a) the Plaintiff failed to demonstrate a prima facie case; (b) there were legitimate non-discriminatory business reasons for altering the plaintiff’s job duties; (c) the employer reasonably accommodated any alleged disability; and (d) the plaintiff failed to establish conduct sufficient to support a claim for intentional infliction of emotional distress.
Thereafter, Ryan & Ryan, LLC submitted a written motion for summary judgment. Judge Victor Bolden granted summary judgment in favor of Ryan & Ryan, LLC’s client as to all of the Plaintiff’s claims.
The United States District Court for the District of Connecticut recently granted the summary judgment motion that Ryan & Ryan, LLC filed on behalf of its client, an automobile rental company at Bradley Airport in Hartford.
In the lawsuit, the Plaintiff alleged that he was subject to discrimination and harassment due to his national origin, and that he was subsequently retaliated against on account of his opposition to said discrimination and harassment.
Ryan & Ryan, LLC conducted fact discovery and marshaled support for the defense theories that (a) the Plaintiff failed to demonstrate a prima facie case of discrimination; (b) a number of the alleged discriminatory events were untimely; (c) the Plaintiff failed to demonstrate that the Defendant had knowledge of any opposition to any alleged discrimination of the basis of national origin; (d) the Plaintiff failed to establish a causal connection between any protected activity and his termination of employment; (e) any alleged harassment was not sufficiently severe or pervasive so as to rise to the level of a hostile work environment; and (f) the Defendant promptly undertook measures to combat any harassment to which the Plaintiff had allegedly been subjected.
Thereafter, Ryan & Ryan, LLC submitted a written motion for summary judgment. David A. Ryan, of Ryan & Ryan, LLC presented oral argument in support of the motion. Judge Stefan R. Underhill granted summary judgment in favor of Ryan & Ryan, LLC’s client as to all of the Plaintiff’s claims.