Feliciano v. Autozone, Inc.
142 Conn. App. 756
Conn. App. Ct.2013Background
- Plaintiff Doris Feliciano is a Black Rastafarian employee at Autozone; transferred to Bloomfield store where Balboni was manager in 2005.
- May 2007, Autozone’s loss-prevention computer flagged 20 transactions linked to a single customer loyalty card; 19 were logged under Feliciano’s CSR number.
- May 16, 2007 Feliciano admitted signing in and leaving the register signed in for others; admitted it was improper per policy.
- Vasquez investigated in Ballou’s presence; Harrison recommended termination; Sikandar, regional manager, terminated Feliciano on May 22, 2007.
- Felician o filed a CHRO complaint July 27, 2007 and EEOC charge; filed this C.F.E.P.A. action April 30, 2009; trial court granted summary judgment to Autozone February 10, 2012.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Disability/disparate treatment for foot injury under 46a-60 | Feliciano was disabled by foot condition; defendant denied light duty. | Plaintiff failed to prove a disability or credible medical evidence. | No genuine issue of material fact; disability claim failed. |
| Sexual harassment under 46a-60(a)(8) | Balboni’s conduct and the text insult constituted sexual harassment. | Complaint failed to plead a statutory basis or specific harassment definition; no notice. | No statutory pleading; summary judgment for defendant on sexual harassment. |
| National origin, religious and race discrimination—prima facie case | Termination was discriminatory based on protected status. | Termination based on admitted policy violation; no discriminatory animus shown; Sikandar final decision-maker. | No inference of discrimination; Prima facie not shown; summary judgment for defendant on counts 1, 2, 5. |
Key Cases Cited
- Rivers v. New Britain, 288 Conn. 1 (2008) (summary judgment standard; plenary review)
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973) (establishes burden-shifting discrimination framework)
- Craine v. Trinity College, 259 Conn. 625 (2002) (discrimination prima facie framework; burden shifting)
- Sturm v. Harb Development, LLC, 298 Conn. 124 (2010) (pleading and identifiable statutory basis rules; scrivener issues)
- Beason v. United Technologies Corp., 337 F.3d 271 (2d Cir. 2003) (disability proof standards under state and federal law)
- Lyon v. Jones, 291 Conn. 384 (2009) (disparate treatment framework application to state law)