Brooks v. Sweeney, 299 Conn. 196

Brooks, an African-American homeowner in Bloomfield, was arrested in 2004 under §19a-220 for failing to repair a septic system leaking onto her property; arrest based on an affidavit by Sweeney alleging repeated violations and noncompliance with health orders.
Sweeney, an environmental sanitarian, and Huleatt, his supervisor, coordinated enforcement of local and state health regulations; the health district is a regional entity serving Bloomfield and West Hartford.
Stone, a neighbor, complained in 2002 about sewage on Brooks’ property, triggering inspections and notices of violation issued by the health district.
Brooks appealed the 2003 order to repair; the health district appeals committee ruled the septic system was a nuisance and health hazard, granting remediation time, and a revised repair plan was later approved in 2004.
Arrests and charges were nolled and dismissed in October 2004; Brooks filed suit in 2006 claiming malicious prosecution, intentional and negligent infliction of emotional distress, §1983 claims, negligent supervision, and direct/indirect liability of the towns.
The trial court granted summary judgment on all counts, finding probable cause for arrest, governmental immunity for §1983 and supervision claims, and derivative immunity for the towns; the appellate court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Probable cause for Brooks’ arrest	Brooks argues facts show no probable cause.	Sweeney acted on the health code and district orders with probable cause.	Probable cause existed; Sweeney entitled to judgment on malicious prosecution and related distress claims.
Qualified immunity for §1983 claims against Sweeney and Huleatt	Claims should overcome immunity due to race-based, unequal treatment.	Actions were objectively reasonable; no clearly established violation.	Sweeney and Huleatt entitled to qualified immunity.
Negligent supervision and identifiable person-imminent harm exception	Huleatt's failure to stop arrest constitutes negligent supervision; exception applies.	No duty breached; immunity applies; no imminent harm.	Assuming the exception applies, negligent supervision claim fails; immunity stands; towns win derivatively.

Bhatia v. Debek, 287 Conn. 397 (2008) (probable cause and malicious prosecution standards; summary judgment context)
Saucier v. Katz, 533 U.S. 194 (2001) (two-step qualified immunity analysis)
Anderson v. Creighton, 483 U.S. 635 (1987) (qualified immunity requires reasonable belief in legality of conduct)
Fleming v. Bridgeport, 284 Conn. 502 (2007) (scope of qualified immunity for public officials)
Willowbrook v. Olech, 528 U.S. 562 (2000) (class of one equal protection standard)
Cadlerock Properties Joint Venture v. Stratford, 253 Conn. 661 (2000) (class-of-one equal protection predicate; factual similarity)
C & H Associates Ltd. Partnership v. Stratford, 122 Conn.App. 198 (2010) (extension of equal protection doctrine to non-class-based claims)