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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Second, as this court previously has indicated, the employee’s motivation is decisive as to whether the expression is a matter of public concern. Daley v. Aetna Life & Casualty Co., supra, 249 Conn. 784. The determinative inquiry is whether the speaker’s interest arises from his status as a private employee. Blum v. Schlegel, 18 F.3d 1005, 1012 (2d Cir. 1994); see also Lewis v. Cowen, 165 F.3d 154, 163-64 (2d Cir. 1999) (must analyze whether speech was calculated to redress personal grievances or whether it was motivated by more general public purpose even if content of speech was generally issue of public concern); Ezekwo v. New York City Health & Hospitals Corp., supra, 940 F.2d 781 (examining whether speaker was “on a mission to protect the public welfare” in criticizing quality of physician training program). A person who is motivated by both personal and civic concerns, however, is not denied the protections of § 31-51q as a matter of law. See, e.g., Donahue v. Windsor Locks Board of Fire Commissioners, supra, 834 F.2d 58. Because a plaintiffs motivation necessarily involves a question of fact to be resolved by a jury; Daley v. Aetna Life & Casualty Co., supra, 778; it should not be concluded as a matter of law that the motivation was purely personal.

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