Connecticut Adopts Narrow Definition of “Supervisor” for Hostile Work Environment Claims
The Connecticut Supreme Court recently adopted the U.S. Supreme Court's relatively narrow definition of “supervisor” for use in determining when employers are liable under the Connecticut Fair Employment Practices Act (CFEPA) for creating or failing to remedy a hostile work environment. The decision provides employers with clarity as the term is not defined by the CFEPA. How We Got Here In O’Reggio v. Commission on Human Rights and Opportunities , SC20847 (Aug. 1, 2024), the plaintiff had worked as an adjudicator for the Connecticut Department of Labor . She sued the department claiming the program service coordinator to whom she reported had subjected her to a hostile work environment. The program service coordinator had authority to assign the plaintiff work, approve leave requests, set schedules, provide training and conduct reviews. The program service coordinator did not have authority, however, to hire, fire or discipline the plaintiff or other employees....