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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‘‘[P]roof of causation can be shown either: (1) indi-
rectly, by showing that the protected activity was fol-
lowed closely by discriminatory treatment, or through
other circumstantial evidence such as disparate treat-
ment of fellow employees who engaged in similar con-
duct; or (2) directly, through evidence of retaliatory
animus directed against the plaintiff by the defendant.’’
(Internal quotation marks omitted.) Ayantola v. Board
of Trustees of Technical Colleges, 116 Conn. App. 531,
539, 976 A.2d 784 (2009).
‘‘Since the court, in deciding a motion for summary
judgment, is not to resolve issues of fact, its determina-
tion of whether the circumstances giv[e] rise to an infer-
ence of discrimination must be a determination of
whether the proffered admissible evidence shows cir-
cumstances that would be sufficient to permit a rational
finder of fact to infer a discriminatory motive. . . . In
the absence of any affirmative evidence of a causal
connection between [the defendant’s] discriminatory
animus toward the plaintiff and the defendant’s [alleged
adverse action], no inference of the defendant’s discrim-
inatory intent can be made.’’ (Citation omitted; internal
quotation marks omitted.) Martinez v. Premier Mainte-
nance, Inc., supra, 185 Conn. App. 449–50.
The plaintiff argues that he presented direct evidence
of causation by demonstrating the defendant’s retalia-
tory animus toward the plaintiff in that ‘‘[the defendant]
directed [the crime center unit] to stop sharing evidence
with [the intelligence center] until [the plaintiff] was
transferred from [the intelligence center] or apolo-
gized.’’ The plaintiff’s argument fails for the following
reasons.
First, the plaintiff has failed to establish a factual
basis connecting the defendant to the alleged retalia-
tion. The plaintiff asserts that ‘‘[i]mmediately after Cit-
ta’s removal from [the intelligence center] . . . [the
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