Section 4-61dd

Citation: Section 4-61dd
Parent Document: Dept. of Public Health v. Estrada, 349 Conn. 223 (2024)
Jurisdiction: Connecticut (state)
Effective Date: 2024-06-11
Original Source: https://www.courtlistener.com/opinion/10131752/dept-of-public-health-v-estrada/ ↗

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have done so. Cf. State v. Heredia, 310 Conn. 742, 761,
          81 A.3d 1163 (2013) (‘‘[W]hen a statute, with reference
          to one subject contains a given provision, the omission
          of such provision from a similar statute concerning a
          related subject . . . is significant to show that a differ-
          ent intention existed. . . . That tenet of statutory con-
          struction is well grounded because [t]he General Assembly
          is always presumed to know all the existing statutes
          and the effect that its action or [nonaction] will have
          [on] any one of them.’’ (Internal quotation marks
          omitted.)).
              Here, Estrada’s grievances were not predicated on a
          claim of whistleblower retaliation. The first grievance
          filed by Estrada grieved the department’s issuance of
          a letter of reprimand on July 7, 2015, contending that
          it was for an issue that did not constitute just cause.
          Specifically, this grievance referenced ‘‘recent events
          involving the process used to confirm the credentials
          of local health directors.’’ (Internal quotation marks
          omitted.) This grievance did not mention or concern
          whistleblower retaliation. It was ultimately denied.
          Estrada’s second grievance ‘‘echoe[d] [the] unresolved
          . . . grievance about reprimand for issues not consti-
          tuting ‘just cause’ ’’ and concerned a reprimand that
          Estrada was issued on November 20, 2015, for ‘‘poor
          work quality and poor judgment.’’ This grievance simi-
          larly did not mention or concern whistleblower retalia-
          tion. It was also denied. Estrada’s third grievance
          concerned her demotion from epidemiologist 4 to epide-
          miologist 3. The department responded to this griev-
          ance by claiming that ‘‘[t]he central issue of this
          grievance is whether the demotion of [Estrada] to [e]pi-
          demiologist 3 was for just cause under the contract.’’
          Although this grievance mentioned that Estrada had
          ‘‘filed a whistleblower complaint regarding the incident
          [that] led to the reprimand,’’ this issue was not discussed
          or resolved during the grievance process. The depart-
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