Robinson v. V. D. (2024)

Citation: Robinson v. V. D. (2024)
Parent Document: Robinson v. V. D. (2024)
Jurisdiction: Connecticut (state)
Effective Date: 2024-11-26
Original Source: https://www.courtlistener.com/opinion/10282961/robinson-v-v-d/ ↗

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persuaded that both the union grievance proceedings
and the proceeding on the civil protection order applica-
tion qualify as either a judicial or quasi-judicial proceed-
ing, and, accordingly, any pertinent statements made
within the context of those proceedings should be
afforded absolute immunity under the litigation privi-
lege.
First, we conclude that the union grievance proceed-
ings are quasi-judicial in nature for purposes of applying
absolute immunity. In Preston v. O’Rourke, 74 Conn.
App. 301, 314 n.6, 811 A.2d 753 (2002), this court recog-
nized and resolved a split in authority over ‘‘whether
communications made in the course of grievance or
arbitration proceedings provided for by collective bar-
gaining agreements should be accorded absolute . . .
immunity.’’ The court concluded that the ‘‘better result
is the protection of absolute immunity.’’ Id. That deter-
mination is consistent with our Supreme Court’s subse-
quent decision in Craig v. Stafford Construction, Inc.,
271 Conn. 78, 80–81, 93, 856 A.2d 372 (2004), in which
it held that an investigation conducted by the internal
affairs division of the city of Hartford’s police depart-
ment constituted a quasi-judicial proceeding for the
purpose of affording absolute immunity to the citizen
whose claim of racial bias had given rise to the investiga-
tion. Although the court in Craig recognized ‘‘the debili-
tating affect that a false allegation of racial discrimina-
tion can have on a police officer’’; id., 95; it nonetheless
enough to be heard by several people that Michael Robinson is ‘crazy,’ has
‘mental health issues,’ should go see his doctor, and should ‘go get the help
you need, bud’; g. Michael Robinson threatened him with force; h. Michael
Robinson had damaged [the defendant’s] vehicle, but then admitted there
was no damage to either vehicle . . . i. The plaintiffs threatened his job,
threatened his livelihood, and ‘knowing that, you know, [Mary Robinson]
is in [human resources], and that he has this information, and I’m done
when I get back to the Coast Guard. I don’t feel safe’; and j. (implied that)
one or both of the plaintiffs committed perjury during the hearing, asking
Mary Robinson whether she thought it was ‘appropriate to not tell the truth
in court?’ ’’
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