230 Conn.App. 847
Conn. App. Ct.2025Background
- Jason Santiago, a New Haven police officer, was terminated for using excessive force during an arrest, including kicking a handcuffed individual in the groin and other inappropriate conduct.
- Santiago's termination followed an internal affairs investigation, a disciplinary hearing, and a review by the New Haven Police Commission.
- Santiago's union (Elm City Local, CACP) filed a grievance under the collective bargaining agreement, leading to arbitration over whether there was "just cause" for the termination.
- The arbitration panel found just cause existed and ruled in favor of the City of New Haven.
- The union sought to vacate the arbitration award in Superior Court, arguing the panel exceeded its powers by considering expert testimony not available at the time of the city's termination decision.
- The Superior Court rejected the union's appeal, and the union further appealed to the Appellate Court.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did the arbitration award conform to the submission? | Panel exceeded authority by relying on post-termination expert evidence | Submission unrestricted; panel could consider all evidence | Award conformed to submission; no error |
| Did the panel manifestly disregard the law? | Panel's reliance on new expert evidence disregarded legal standards | Plaintiff abandoned this claim at trial and failed to brief on appeal | Declined to review due to abandonment |
| Scope of court review on unrestricted submission | Court should scrutinize panel's evaluation and limit evidence to what city considered | Courts may not review evidence or legal/factual determinations in such cases | Limited to verifying panel acted within powers; |
| no review of evidence | |||
| Was the panel's reliance on Daigle's opinion improper? | Arbitrators could only consider evidence city relied upon for discharge | Arbitrators could consider all relevant evidence; submission was broad | Panel acted within authority to consider evidence |
Key Cases Cited
- Blondeau v. Baltierra, 337 Conn. 127 (sets standard for vacating arbitral awards when powers exceeded)
- Garrity v. McCaskey, 223 Conn. 1 (standard for manifest disregard of the law in arbitration)
- Board of Education v. Waterbury Teachers Assn., 196 Conn. App. 463 (explains unrestricted submissions)
- Comprehensive Orthopaedics & Musculoskeletal Care, LLC v. Axtmayer, 293 Conn. 748 (scope of court review on arbitral decisions)
- Middlebury v. Teamsters Local Union No. 677, 57 Conn. App. 223 (review limited to comparison of award to submission in unrestricted arbitration)