Section 31-51q

Citation: Section 31-51q
Parent Document: Cotto v. United Technologies Corp., 251 Conn. 1 (1999)
Jurisdiction: Connecticut (state)
Effective Date: 1999-10-12
Original Source: https://www.courtlistener.com/opinion/7898264/cotto-v-united-technologies-corp/ ↗

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*46First, as the Appellate Court correctly observed, internal employment policies are not a matter of public concern. Id., 631-32; see also Ezekwo v. New York City Health & Hospitals Corp., 940 F.2d 775, 781 (2d Cir.), cert. denied, 502 U.S. 1013, 122 S. Ct. 657, 116 L. Ed. 2d 749 (1991) (personnel decision is not matter of public concern). Whether an expression results from or relates to an employer’s policy and whether the event underlying the subject of the employee’s expression is primarily of significance to that employee, however, do not diminish the public importance of his concerns. See, e.g., Branti v. Finkel, 445 U.S. 507, 515-16, 100 S. Ct. 1287, 63 L. Ed. 2d 574 (1980) (plaintiff s protest of employer’s policy requiring employees to affiliate with political campaigns protected by first amendment because policy constitutes coercion of belief in violation of fundamental constitutional rights); Elrod v. Burns, supra, 427 U.S. 347 (employees of sheriffs office who were not civil servants could not be dismissed for failing to join certain political party where office policy was to employ only such employees affiliated with sheriffs party). Such personal concerns do not alone convert the matter *47into an unprotected, purely private grievance. See, e.g., Givhan v. Western Line Consolidated School District, supra, 439 U.S. 412-13 (speech could be of public interest where teacher criticized school’s employment policies and practices that she considered racially discriminatory); Donahue v. Windsor Locks Board of Fire Commissioners, 834 F.2d 54, 58 (2d Cir. 1987) (firefighter’s claims of gender based discrimination and Freedom of Information Act violations concerned matters of public interest even though complaints based on fact that wife’s job application was rejected and firehouse’s practice of closed door board of fire commissioners meetings).

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