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DRAFT FOR ATTORNEY REVIEW — NOT FINAL

§ 46a-58

Citation
§ 46a-58
Parent Document
Connecticut Judicial Branch v. Gilbert, 343 Conn. 90 (2022)
Jurisdiction
Connecticut (state)
Effective Date
2022-04-26

Other Sections in This Document (128)

Full Text

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ing that courts have liberally interpreted Title VII’s
          standing provisions to effectuate remedial purpose of
          law); Section-By-Section Analysis of H.R. 1746, The
          Equal Employment Opportunity Act of 1972, 118 Cong.
          Rec. 7166, 7168 (1972) (‘‘the individual’s rights to redress
          are paramount under the provisions of Title VII’’).
             The branch’s third argument is that litigation of a Title
          VII claim in a court affords the defendant/respondent
          various procedural protections—the rights to a jury
          trial, to remove an action from state court to federal
          court, to full civil discovery and formal rules of evi-
          dence—that are not available in an administrative adju-
          dication. The branch contends that allowing a state fair
          employment practices agency such as the commission
          to find and penalize Title VII violations under state law
          would upset a carefully calibrated federal scheme that
          balances the availability of remedies with important pro-
          cedural protections.
             The United States Court of Appeals for the Second
          Circuit has rejected this very argument, finding no viola-
          tion of federal law despite the contention that allowing
          a complainant to bring a Title VII claim before the
          commission, pursuant to § 46a-58 (a), would circumvent
          federal procedural protections. See Shelton v. Hughes,
          578 Fed. Appx. 53, 55 (2d Cir. 2014). The branch’s claim
          also runs headlong into the United States Supreme
          Court decisions holding that a state agency’s adjudica-
          tion of an employment discrimination claim, which has
          been reviewed and affirmed by the state’s appellate
          courts, affords sufficient procedural protections to have
          preclusive effect with respect to a subsequent action
          in federal court addressing the same alleged conduct.
          See, e.g., Kremer v. Chemical Construction Corp., supra,
          456 U.S. 484 (concluding that ‘‘[the] panoply of proce-
          dures [provided by the New York State Division of
          Human Rights hearing], complemented by administra-
          tive as well as judicial review,’’ was more than sufficient
Page 54                   CONNECTICUT LAW JOURNAL                         April 26, 2022