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DRAFT FOR ATTORNEY REVIEW — NOT FINAL

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

Other Sections in This Document (85)

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concluded ‘‘that the policy of encouraging citizen com-
       plaints against those people who wield extraordinary
       power within the community outweighs the need to
       protect the reputation of the police officer against
       whom the complaint is made.’’ Id., 96.
         Here, as was the case in Craig, the Coast Guard
       officials who heard the union grievance may not have
       possessed all of the aforementioned enumerated pow-
       ers that we look to in determining whether proceedings
       are quasi-judicial. See Priore v. Haig, supra, 344 Conn.
       648. Such deficit is not dispositive, however, of whether
       the proceeding was quasi-judicial in nature. Rather, we
       look to the overall facts and circumstances in making
       our determination.
          The defendant was a federal employee and a member
       of a collective bargaining unit, and he initiated a formal
       grievance process as set forth in the relevant collective
       bargaining agreement. The matter was then adjudicated
       by Coast Guard administrative officials, who ascer-
       tained and evaluated the relevant facts and exercised
       judgment and discretion in applying all relevant rules,
       regulations and procedures applicable to the union
       grievance process. See, e.g., 5 U.S.C. § 7121 (setting
       forth minimum requirements for grievance procedures
       in collective bargaining agreements governed by federal
       labor relations statutes). The officials’ resolution of the
       grievance had the potential to impact not only the
       employment status and other rights of the defendant as
       the complainant but potentially those of the plaintiffs,
       other Coast Guard personnel engaged in the hiring pro-
       cess, and the recipient of the job sought by the defen-
       dant. Accordingly, we perceive nothing of import in the
       present case that warrants treating the union grievance
       proceedings differently than the proceedings at issue
       in Craig or Preston. Moreover, as a matter of sound
       policy, extending absolute immunity to the union griev-
       ance proceedings helps to alleviate any possible chilling
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