Harris v. Dept. of Correction, 154 Conn.App. 425

Harris, African-American, began as a correction officer in 1994 with the Department of Correction.
On June 27, 2000, supervisors observed Harris watching television; surveillance showed about 22 minutes; he denied the conduct.
Harris received a 30-day suspension for neglect of duties and untruthfulness; past disciplinary history was noted in the sanction.
In 2001–2002, Harris filed EEOC/CHRO complaints alleging race and color discrimination; CHRO dismissed, later reaffirmed, release of jurisdiction followed.
In 2009 Harris added Title VII claim; district court remanded; state court later granted summary judgment in defendant’s favor on grounds of no prima facie case.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Prima facie case of discrimination established?	Harris argues circumstances show discrimination given discipline history and comparator.	Department contends no admissible evidence of similarly situated comparator or discriminatory motive.	No genuine issue; no prima facie case established.
Use of past disciplinary history and video evidence	Plaintiff contends videotape and history show pretextual discipline.	Defendant asserts legitimate business decision; past history relevant under policy.	Court affirmed summary judgment; evidence insufficient to show discrimination.

Bonington v. Westport, 297 Conn. 297 (2010) (framework for summary judgment and burden of proof)
Jacobs v. General Electric Co., 275 Conn. 395 (2005) (pretext and burden-shifting in discrimination actions)
McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973) (prima facie case and burden-shifting framework)
Lyon v. Jones, 291 Conn. 384 (2009) (interplay of state and federal discrimination analyses)
Jackson v. Water Pollution Control Authority, 278 Conn. 692 (2006) (pro se arguments and review limits)
Oliphant v. Commissioner of Correction, 274 Conn. 563 (2005) (self-representation and procedural compliance)