Feliciano v. Autozone, Inc., 111 A.3d 453

Felíciano, a black Rastafarian woman, was employed by AutoZone and terminated May 22, 2007 for allegedly misusing a customer loyalty card under loss-prevention policy.
Balboni, the Bloomfield store manager, made repeated discriminatory remarks about Rastafari and Jamaica, including denigrating comments about hair and religion.
A loss-prevention report flagged 20 transactions; 19 were under Felíciano’s CSR number and one under another employee’s number (Davis), who was not investigated.
Felíciano filed a CHRO complaint July 27, 2007 and a federal EEO complaint; EEOC issued right-to-sue April 7, 2009; CHRO jurisdiction released April 14, 2009; she filed suit April 30, 2009 under Connecticut FEPA.
Trial court granted summary judgment for AutoZone on all counts; Appellate Court affirmed except on the sexual harassment claim; this Court grants certification and addresses the hostile environment claim.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Felíciano proved a prima facie discriminatory termination	Feliciano shows Balboni’s animus and evidence of disparate treatment	AutoZone had legitimate nondiscriminatory reasons; no causal link shown	No inference of discrimination; judgment affirmed on termination claim
Whether the sexual harassment claim supported a hostile work environment	Balboni’s conduct was pervasive and severe toward Felíciano	Evidence did not meet severe/pervasive standard and defendant not on notice of the §46a-60 (a)(8)(C) theory	Court holds hostile environment claim present; remands for proceedings on that claim

McDonnell Douglas Corp. v. Green, 411 U.S. 792 (U.S. 1973) (establishes the prima facie framework for discrimination claims)
Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133 (U.S. 2000) (disbelief of employer’s reasons can support but not alone prove discrimination)
St. Mary's Honor Ctr. v. Hicks, 509 U.S. 502 (U.S. 1993) (burden not satisfied by mere disbelief of employer’s reasons)
Board of Education v. CHRO, 266 Conn. 492 (Conn. 2003) (a plaintiff must show prima facie discrimination; employer’s reasons may be pretext)
Perez-Dickson v. Bridgeport, 304 Conn. 483 (Conn. 2012) (dispositive for inference via pattern or evidence of disparity)
Quinn v. Green Tree Credit Corp., 159 F.3d 759 (2d Cir. 1998) (illustrates pervasiveness standard for hostile environment claims in some contexts)
Patino v. Birken Mfg. Co., 304 Conn. 679 (Conn. 2012) (defines objective/subjective severity in hostile environment analysis)
Staub v. Proctor Hospital, 562 U.S. 411 (U.S. 2011) (imputing supervisor's discriminatory animus to employer if proximate cause)