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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)

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U.S. 957, 125 S. Ct. 1731, 161 L. Ed. 2d 596 (2005); Patino
          v. Birken Mfg. Co., 304 Conn. 679, 708, 41 A.3d 1013
          (2012) (‘‘[garden-variety] emotional distress claims gen-
          erally merit $30,000 to $125,000 awards’’ (internal quota-
          tion marks omitted)).35
             However, because the referee made several findings
          of fact regarding the complainant’s need for medication,
          we are unable to conclude that the improperly admitted
          evidence did not factor into her damages calculation.
          On remand for a new hearing in damages, the complain-
          ant will present evidence of garden-variety emotional
          distress only, and the referee will assess damages in
          an amount deemed reasonable and appropriate in light
          of that evidence.36
                                                IV
                                 INJUNCTIVE RELIEF
             Finally, we turn to the issue of whether the trial
          court properly vacated the injunction requiring that the
          branch ‘‘give the complainant the option of returning
          to the Danielson courthouse,’’ from where she had been
          transferred after reporting the abuse to her superiors.37
             35
                We express no opinion as to the issues presented by the pending appeal
          in Commission on Human Rights & Opportunities v. Cantillon, 340 Conn.
          909, 909–10, 264 A.3d 94 (2021), such as whether a damages award of less than
          $30,000 for garden-variety emotional distress is presumptively insufficient.
             36
                The branch should understand that the hearing in damages is de novo
          and, therefore, that the size of the award on remand may be less than, the
          same as, or greater than the amount of the vacated award.
             37
                We note that there is some question as to whether this issue is moot.
          At the time of the hearing in February, 2017, the complainant testified that
          she had been reassigned to Danielson. Although there was some possibility
          that she would again be transferred from that courthouse, her supervisor
          had represented to her that he was going to try to keep her there. Also, in
          the nearly five years that have since passed, Marco has retired, and the
          complainant has opted not to participate in the present appeal. It is unclear,
          then, whether the injunctive relief at issue remains part of a live controversy.
          Because the parties have not represented otherwise, however, we proceed
          on the assumption that the issue is not moot, and we leave it to the commis-
          sion to make a final determination on remand. See, e.g., Jean-Baptiste v.
          District of Columbia, 958 F. Supp. 2d 37, 49 (D.D.C. 2013) (‘‘[a] request for
April 26, 2022                  CONNECTICUT LAW JOURNAL                                       Page 81