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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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-
         ment’s conclusion with respect to this grievance was
Page 26                   CONNECTICUT LAW JOURNAL                       June 11, 2024

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