Michel v. Hartford, 226 Conn. App. 98 (2024)

Citation: Michel v. Hartford, 226 Conn. App. 98 (2024)
Parent Document: Michel v. Hartford, 226 Conn. App. 98 (2024)
Jurisdiction: Connecticut (state)
Effective Date: 2024-06-11
Original Source: https://www.courtlistener.com/opinion/10131855/michel-v-hartford/ ↗

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to a cause of action under . . . the [f]irst [a]mend-
       ment.’’ Id., 125. The plaintiff in that case, a public school
       teacher, alleged that she suffered ongoing retaliation
       as a result of her assistance to a fellow employee regard-
       ing a gender discrimination claim. Id., 123–24. The plain-
       tiff alleged that she provided assistance by, among other
       things, being listed as a witness for the fellow employee
       in her discrimination lawsuit against the school district.
       Id., 123. The plaintiff alleged that she subsequently was
       subjected to a series of adverse personnel actions by
       the school district, its board of education, and certain
       administrators and, therefore, filed her first retaliation
       action (1996 lawsuit), which ultimately settled. Id. The
       plaintiff filed a second retaliation action, the lawsuit at
       issue in Konits, based on her claim that she was retali-
       ated against for filing the 1996 lawsuit. Id., 124. The
       United States District Court rendered summary judg-
       ment in favor of the defendants after concluding that
       the plaintiff’s 1996 lawsuit was not speech on a matter
       of public concern.15 Id.
           The Second Circuit vacated the judgment of the Dis-
       trict Court and remanded the case for further proceed-
       ings on the plaintiff’s retaliation claim. Id., 126. The
       Second Circuit explained that, ‘‘[b]ecause [the plain-
       tiff’s] 1996 lawsuit was predicated on speech about
       gender discrimination against a fellow employee that
       directly implicated the access of the courts to truthful
       testimony,’’ it disagreed with the District Court’s assess-
       ment that the lawsuit centered around the plaintiff’s
       dissatisfaction with the terms and conditions of her
       employment. Id., 125–26. The Second Circuit opined
       that the plaintiff’s motive in speaking out had the
       ‘‘ ‘broader public purpose’ ’’ of assisting the fellow
          The Second Circuit explained that, ‘‘if [the plaintiff’s] 1996 lawsuit
         15

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