Martinez v. CONNECTICUT, STATE LIBRARY, 2011 U.S. Dist. LEXIS 107848

Martinez, a Hispanic female and Connecticut library employee since 1988, claims she worked outside her clerk typist classification and faced increased workload after a 1996 grievance.
She asserts Minow (white) and supervisor Taylor (white) subjected her to harassment based on race/national origin, including nine derogatory remarks and a coma-related joke.
In 2006, Martinez was involved in a bathroom confrontation with Minow; an investigation, led by Carey, resulted in a one-day suspension and possible EAP referral.
Discipline followed a CHRO complaint (Dec 14, 2006) and an internal investigation; Martinez later filed suit in 2009 alleging Title VII, ADA, and CFEPA claims, plus IIED.
The court grants summary judgment for the State Library on all claims, finding no genuine issues of material fact supporting discrimination, retaliation, hostile environment, ADA, or IIED claims.
The court recognizes that the DA/ADA analysis involves whether Martinez is disabled; it ultimately finds no actionable disability and that the accommodation of a space heater did not create an ADA violation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Martinez proved Title VII discrimination	Martinez asserts race/national origin discrimination in denial of a class update and related discipline.	Defendant contends the denial of a class update was not an adverse action and the discipline was a legitimate, non-discriminatory result of conduct.	No genuine issue; no adverse action or pretext established for discrimination.
Whether Martinez proved Title VII retaliation	Martinez alleges CHRO filing and subsequent suspension show retaliation.	Suspension followed a formal investigation for Workplace Violence; no causal link shown between protected activity and discipline.	No genuine dispute; no actionable retaliation.
Whether Martinez proved Title VII hostile work environment	Nine comments over twenty years created a pervasively hostile environment.	Comment frequency and severity were insufficient; interactions were not pervasive enough to alter conditions of employment.	No hostile work environment under Title VII.
Whether Martinez proved ADA/CFEPA disability claims and retaliation	Asthma constitutes a disability and denial of accommodation harmed her; retaliation possible.	Martinez not disabled under ADA; accommodation provided (space heater) was reasonable; no retaliation linked to disability.	ADA summary judgment in favor of Defendant; CFEPA disability claims likewise rejected.

McDonnell Douglas Corp. v. Green, 411 U.S. 792 (Supreme Court, 1973) (establishes burden-shifting framework for discrimination claims)
Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133 (Supreme Court, 2000) (burden shifting; pretext analysis standard clarified)
Lovejoy-Wilson v. NOCO Motor Fuel, Inc., 263 F.3d 208 (2d Cir. 2001) (one-week suspension can be adverse action; precedent on retaliation)
Clark Cnty. School Dist. v. Breeden, 532 U.S. 268 (Supreme Court, 2001) (temporal proximity as evidence of retaliation must be examined carefully)