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

Citation: Begley v. State, 234 Conn. App. 820 (2025)
Parent Document: Begley v. State, 234 Conn. App. 820 (2025)
Jurisdiction: Connecticut (state)
Effective Date: 2025-09-02
Original Source: https://www.courtlistener.com/opinion/10664577/begley-v-state/ ↗

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plaintiff first must establish a prima facie case, then
the burden of production shifts to the defendant to
rebut the presumption of discrimination by articulating
a legitimate, nondiscriminatory reason for its employ-
ment decision. . . . Once the defendant offers a legiti-
mate, nondiscriminatory reason, then the plaintiff has
the burden to prove by a preponderance of the evidence
that the proffered reason is pretextual.’’ (Citations omit-
ted; footnote in original; footnote omitted; internal quo-
tation marks omitted.) Lassen v. Hartford, 223 Conn.
App. 285, 290–91, 308 A.3d 564 (2024).
The plaintiff claims that the trial court erred when
it determined that no genuine issue of material fact
existed as to whether he had failed to establish a prima
facie case of retaliation in that he had not presented
any evidence demonstrating a causal connection
between his filing of the report and his transfer out of
the intelligence center three years later.12 We are not
persuaded.
‘‘To establish a prima facie case of retaliation, a plain-
tiff must show (1) that he participated in a protected
activity; (2) that the defendant knew of the protected
activity; (3) an adverse employment action against him;
and (4) a causal connection between the protected
activity and the adverse employment action.’’ (Internal
quotation marks omitted.) Id., 290–91 n.5. Implicit in the
requirement that the plaintiff show a causal connection
between his participation in a protected activity and the
alleged adverse action is a showing that the defendant
knew or was otherwise aware that the plaintiff had
engaged in that protected activity. See, e.g., Forestier
v. Bridgeport, 223 Conn. App. 298, 319, 308 A.3d 102
(2024).
12
The plaintiff claims that ‘‘[t]he court did not appear to read or review [his]
exhibits’’ and ‘‘ignored much of the relevant factual detail and supporting
arguments submitted by the plaintiff.’’ Our review of the record reveals no
basis for these claims.
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