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/ ↗

Full Text

2,291 chars

agree that, as long as the self-reporting employee can
       prove the necessary causal nexus between the act of
       reporting and the ensuing discipline, that employee is
       entitled to receive whistleblower protection for reporting
       his or her own error.
          There are two important phrases in § 4-61dd that
       support this conclusion. First, the statute provides that
       ‘‘[a]ny person’’ who discloses covered information is
       included under the statute. General Statutes (Rev. to
       2017) § 4-61dd (a). Second, the statute covers ‘‘any mat-
       ter involving’’ various types of misconduct specified in
       the statute. General Statutes (Rev. to 2017) § 4-61dd
       (a). The broad language of each of these phrases is
       consistent with the remedial purpose of § 4-61dd, which
       is to ‘‘root out’’ misconduct in government. Hartford
       County Sheriffs Dept. Communities Charities Assn.
       v. Blumenthal, 47 Conn. Supp. 447, 459, 806 A.2d 1158
       (2001). It is well settled that remedial statutes are inter-
       preted broadly to effectuate their purpose. See, e.g.,
       Thames Talent, Ltd. v. Commission on Human Rights
       & Opportunities, 265 Conn. 127, 137, 827 A.2d 659
       (2003).
          We recognize that this court has previously con-
       cluded that the word ‘‘any’’ ‘‘can have a variety of mean-
       ings,’’ depending on the statutory context, including ‘‘all,
       every, some or one.’’ (Internal quotation marks omit-
       ted.) Ames v. Commissioner of Motor Vehicles, 267
       Conn. 524, 531, 839 A.2d 1250 (2004). But, as the depart-
       ment concedes, to the extent that there is ambiguity in
       the language of the statute, extratextual sources resolve
       any ambiguity in favor of a broader interpretation. See
       General Statutes § 1-2z (permitting resort to extratex-
       tual sources if statutory language is ambiguous). First,
       it is unlikely that the legislature would have wanted
       employees disciplined for bringing their own actions
       to light, as that would discourage disclosure and under-
       mine the statutory goals. See, e.g., 45 H.R. Proc., supra,
Page 34                   CONNECTICUT LAW JOURNAL                         0, 0

Other Sections in This Document (239)

Full Text