Begley v. State, 234 Conn. App. 820 (2025)

the intelligence center in March, 2019, was retaliatory,
       pursuant to § 46a-60 (b) (4), for his filing of the report
       in 2016.
          On April 17, 2023, the defendant filed a motion for
       summary judgment on the grounds that the plaintiff
       had failed to establish a prima facie case for retaliation
       and that, even if he had, there existed legitimate, nonre-
       taliatory reasons for the plaintiff’s transfer, and the
       plaintiff could not establish that the articulated reasons
       were a pretext for unlawful retaliation. The defendant
       argued that the plaintiff failed to demonstrate any
       causal connection between the plaintiff’s filing of the
       report and his transfer three years later. The defendant
       further argued that the plaintiff was transferred ‘‘due
       to operational need as part of a reorganization.’’ Along
       with his memorandum of law in support of his motion,
       the defendant submitted several exhibits for the court’s
       consideration.
          The plaintiff filed an objection to the defendant’s
       motion for summary judgment, arguing that genuine
       issues of material fact existed as to whether there was
       a causal connection between his filing of the report and
       his transfer. He argued that the lapse of three years
       between the two events does not defeat a causal con-
       nection because the defendant was not in a position to
       retaliate against the plaintiff until shortly before the
       plaintiff’s transfer. The plaintiff further argued that
       there was a genuine issue of material fact as to whether
       the defendant’s claim that he was transferred for man-
       power reasons stemming from reorganization was pre-
       textual. Like the defendant, the plaintiff submitted sev-
       eral exhibits in support of his position.8
       counts two and three. The plaintiff filed a motion for permission to file
       an interlocutory appeal, which the court denied. The plaintiff thereafter
       withdrew the second count of his complaint as to the defendant only, thereby
       disposing of all claims against the defendant, in order to proceed with this
       appeal. See Practice Book §§ 61-3 and 61-4.
          8
            The defendant thereafter filed a reply brief. The defendant also moved
       to strike several of the plaintiff’s exhibits. The trial court indicated to counsel
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