Perez-Dickson v. City of Bridgeport, 304 Conn. 483

Perez-Dickson, an African-American/ Puerto Rican principal, alleges retaliation for reporting student abuse by white teachers.
She was transferred/demoted from Beardsley School to Newfield, then Roosevelt School, amid investigations/several internal reviews.
In 2005 she was placed on paid administrative leave following allegations of abuse; department found allegations unsubstantiated but noted concerns.
Plaintiff sued under § 31-51q and § 17a-101e; also alleged race discrimination under 42 U.S.C. §§ 1981, 1983 and emotional distress.
Jury returned verdicts awarding damages across claims; trial court later remitted/adjusted amounts and awarded fees/interest.
Defendants moved for directed verdict; issue whether Garcetti bars § 31-51q and whether § 17a-101e creates a private right.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does Garcetti bar § 31-51q retaliation claim based on official duties speech?	Perez-Dickson argues state constitution grounds may survive Garcetti.	Garcetti bars speech made pursuant to official duties from First Amendment protection.	Garcetti bars § 31-51q claim; affirmed.
Whether § 17a-101e provides a private cause of action and thus subject-matter jurisdiction exists?	§ 17a-101e creates a private right to sue.	No private cause of action; lacks jurisdiction.	§ 17a-101e does not provide a private right; lack of jurisdiction.
Did plaintiff prove race discrimination under § 1981/1983?	She was treated differently from white employees; evidence supports discrimination.	No causation; comparators not sufficiently similar; no pattern.	Directed verdict for defendants upheld; no proof of intentional race discrimination.
Was the claim for intentional infliction of emotional distress properly denied?	Actions like immediate leave and transfers were extreme and outrageous.	Conduct was workplace-typical; not extreme/outrageous.	Trial court erred; directed verdict for defendants granted; judgment reversed.

Garcetti v. Ceballos, 547 U.S. 410 (U.S. 2006) (public employee speech under official duties not protected)
Connick v. Myers, 461 U.S. 138 (U.S. 1983) (public employee speech on public concern balancing test)
St. Mary's Honor Center v. Hicks, 509 U.S. 502 (U.S. 1993) (burden-shifting framework and pretext evaluation in discrimination cases)
Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133 (U.S. 2000) (pretext and ultimate burden of proving discrimination)
Board of Education v. Commission on Human Rights & Opportunities, 266 Conn. 492 (Conn. 2003) (statistical/disparate treatment standards; discrimination analysis)
New Haven v. Bonner, 272 Conn. 489 (Conn. 2005) (exceptional circumstances for reviewing unpreserved grounds)
State v. Gore, 288 Conn. 770 (Conn. 2008) (coextensiveness of state and federal constitutional rights)
Craine v. Trinity College, 259 Conn. 625 (Conn. 2002) (McDonnell Douglas framework in discrimination)
Weinstock v. Columbia University, 224 F.3d 33 (2d Cir. 2000) (discrimination burden shifting and pretext evaluation)
Ottaviani v. State University of New York, 875 F.2d 371 (2d Cir. 1989) (circumstantial evidence and pattern of discrimination standards)
Aragon v. Republic Silver State Disposal, Inc., 292 F.3d 654 (9th Cir. 2002) (statistical evidence must show stark pattern to prove discrimination)