Hartford Police Dept. v. Commission on Human Rights & Opportunities, 347 Conn. 241

Khoa Phan, a Vietnamese probationary Hartford police officer, completed academy training and received generally satisfactory evaluations until encounters with Sergeant Steven Kessler in Jan–Feb 2011.
Kessler made racially derogatory remarks about Phan's accent/ethnicity, warned Phan he 'won't be around long,' and sent a memo to the police academy commander describing Phan as argumentative.
After Kessler's complaints, other supervisors for the first time documented argumentative/confrontational conduct, resurrected a year‑old lost hat‑piece report (with alleged falsification), and relied on an unverified account of a Taser incident.
Chief of Police Roberts terminated Phan in June 2011, citing untruthfulness about the hat piece, concealment of daily observation reports, and dishonesty about the Taser incident; Phan alleged termination was due to his Vietnamese ancestry.
A CHRO human rights referee found discrimination, a trial court affirmed the referee, the Appellate Court reversed for lack of substantial evidence, and the Connecticut Supreme Court granted certification and reversed the Appellate Court, restoring the referee's decision.

Issue	Plaintiff's Argument (Phan)	Defendant's Argument (Hartford PD)	Held
Whether the circumstances give rise to an inference of discrimination via transferred intent / cat’s‑paw theory	Kessler's racist remarks and memo tainted other supervisors' reviews and influenced the ultimate decision‑maker, creating a causal nexus	No evidence Kessler intended termination or that his memo influenced the final decision; no direct proof Roberts relied on Kessler	Yes. Court held transferred intent/cat’s‑paw applies; referee reasonably found Kessler intended harm and that his animus influenced reviews and the termination decision
Whether the employer's proffered reasons were pretextual	The hat‑piece reinvestigation, the Taser memo, and the missing‑reports allegations were one‑sided, inconsistent, and unreliable, so they are false and pretextual	The documentation and memos show contemporaneous poor performance and justify termination	Yes. Court held substantial evidence supports the referee's credibility findings that the reasons were false/inadequately investigated and therefore pretextual
Proper standard of review for referee findings	Appellate Court improperly reweighed credibility and substituted its judgment for the referee	Appellate Court asserted insufficient evidence supported referee findings	Court held reviewing courts must apply a highly deferential substantial‑evidence standard and may not substitute their assessment of witness credibility

McDonnell Douglas Corp. v. Green, 411 U.S. 792 (establishes prima facie framework for disparate treatment claims)
Staub v. Proctor Hospital, 562 U.S. 411 (recognizes cat’s‑paw liability where a biased subordinate intended to cause an adverse action and that act was a proximate cause)
Feliciano v. Autozone, Inc., 316 Conn. 65 (Connecticut application of transferred intent/cat’s‑paw requires a causal nexus between biased actor and termination)
United Techs. Corp. v. Commission on Human Rights & Opportunities, 72 Conn. App. 212 (Connecticut Appellate Court on transfer of intent where a biased subordinate’s report tainted decisionmaker)
Board of Education v. Commission on Human Rights & Opportunities, 266 Conn. 492 (describes substantial‑evidence, deferential review of administrative factfinding and pretext analysis)
Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133 (falsity of employer’s reasons may permit an inference of intentional discrimination)