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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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Accordingly, we affirm the judgment of the trial court
          with respect to the Title VII issue.
                                                II
          PREJUDGMENT AND POSTJUDGMENT INTEREST—
                    SOVERIEGN IMMUNITY
            We next consider whether the trial court properly
          concluded that the state has waived its sovereign immu-
          nity with respect to prejudgment and postjudgment
          interest on awards under § 46a-86. The commission con-
          tends that, by waiving immunity to suit and to liability
          under § 46a-51 (10), which provides in relevant part
          supra, 2014 WL 1032765, *3 n.5, *4 n.8 (citing Connecticut cases). The
          appendix to the commission’s trial brief contains more than 70 decisions,
          dating back to 1999, in which the commission resolved Title VII claims
          under the auspices of § 46a-58 (a). The commission is not alone in this
          regard. See Employment Security Commission v. Peace, 128 N.C. App. 1,
          7–9, 493 S.E.2d 466 (1997) (North Carolina State Personnel Commission
          adjudicated Title VII claim), aff’d in part and dismissed in part, 349 N.C.
          315, 507 S.E.2d 272 (1998); see also Carey v. New York Gaslight Club, Inc.,
          supra, 598 F.2d 1257–58 (New York State Division of Human Rights resolved
          ‘‘Title VII claim’’ in contested hearing ‘‘pursuant to Title VII’’). The commis-
          sion also is not the only state agency to be authorized under Connecticut
          law to identify violations of federal statutes and to impose remedies for those
          violations under state law. See, e.g., General Statutes § 36a-606a (money
          laundering); General Statutes § 36a-719f (mortgage loan servicing); General
          Statutes § 36a-812 (debt collection); General Statutes § 36a-853 (student
          loan servicing).
             As early as 2006, following the decision of this court in Commission on
          Human Rights & Opportunities v. Board of Education, supra, 270 Conn. 665,
          the commission formally took the position that a ‘‘complainant’s inclusion
          of . . . § 46a-58 (a) in her complaint affidavit allows [the commission] to
          convert her federal claims into claims under Connecticut’s antidiscrimina-
          tion laws, and to award damages for emotional distress pursuant to . . .
          § 46a-86 (c).’’ Commission on Human Rights & Opportunities ex rel. DiMi-
          cco v. Neil Roberts, Inc., No. 0420438, 2006 WL 4753465, *4 (C.H.R.O. Septem-
          ber 12, 2006). As we discussed, reasonable, long-standing, formally
          articulated interpretations of a statute by an administrative agency are enti-
          tled to deference. Although the branch contends that the commission’s
          interpretation is not time-tested and, thus, not entitled to deference, the
          branch fails to explain why a string of decisions going back more than
          fifteen years does not satisfy that standard.
Page 60                   CONNECTICUT LAW JOURNAL                        April 26, 2022