Heyward v. Judicial Dep't of Conn., 176 A.3d 1234

Theresa Heyward, an African-American administrative clerk and the only nonwhite employee in the Meriden clerk’s office, sued the Judicial Department under Conn. Gen. Stat. § 46a-60(a) alleging hostile work environment and race discrimination by her supervisor, Robert Axelrod.
Heyward’s amended complaint alleged: two racial remarks (one directed at a third party), denial of vacation/medical leave while others received time off, public yelling/interruption by Axelrod, a disciplinary e-mail placed in her personnel file, and perceived favoritism toward a coworker.
The trial court previously dismissed several counts as to the state and all counts as to Axelrod; the remaining hostile work environment and race discrimination counts against the state were later challenged by the state’s motion to strike.
The trial court granted the state’s motion to strike, concluding Heyward’s pleadings failed to allege sufficient facts for either claim; Heyward appealed.
The Appellate Court reviewed the strike de novo and affirmed: it held the alleged conduct was not sufficiently severe or pervasive to support a hostile work environment claim and did not amount to an adverse employment action required for a disparate-treatment race discrimination claim.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether pleadings stated hostile work environment under § 46a-60(a)	Heyward argued her allegations (racial remarks, denial of leave, yelling, favoritism, disciplinary e-mail) met the "severe or pervasive" standard.	State argued the alleged incidents were isolated/routine workplace disputes and insufficiently severe or pervasive.	Affirmed strike: two racial remarks (one toward a third person) and routine workplace grievances were not severe or pervasive.
Whether pleadings alleged adverse employment action for disparate-treatment race discrimination	Heyward argued the factual allegations (disciplinary e-mail, public reprimand, denial of leave) implied an adverse employment action.	State argued reprimands, placement of a disciplinary e-mail, and yelling do not constitute materially adverse employment actions absent termination, demotion, loss of pay, or materially diminished responsibilities.	Affirmed strike: plaintiff failed to allege a materially adverse change in terms/conditions of employment; reprimands and warnings alone insufficient.

Brittell v. Dept. of Correction, 247 Conn. 148 (Conn. 1998) (defines "severe or pervasive" hostile work environment standard under Connecticut law)
Feliciano v. AutoZone, Inc., 316 Conn. 65 (Conn. 2015) (quantity, frequency, and severity of slurs considered cumulatively for hostile work environment)
Harris v. Forklift Systems, Inc., 510 U.S. 17 (U.S. 1993) (mere utterance of an epithet does not alone create actionable hostile work environment)
McDonnell Douglas Corp. v. Green, 411 U.S. 792 (U.S. 1973) (framework for disparate-treatment prima facie case)
Quinn v. Green Tree Credit Corp., 159 F.3d 759 (2d Cir. 1998) (two isolated incidents held insufficient for hostile work environment)