Spiotti v. Town of Wolcott
163 A.3d 46
| Conn. | 2017Background
- Doreen Spiotti, a Wolcott police officer and union member, was terminated after an internal investigation found she made false statements in a complaint to an ombudsman.
- Spiotti pursued and exhausted the union grievance/arbitration process before the Connecticut State Board of Mediation and Arbitration, which concluded there was just cause for termination.
- Spiotti then sued the town alleging statutory claims: retaliation/protected speech under Conn. Gen. Stat. § 31-51q and discrimination under § 46a-60(a)(4).
- The town moved for summary judgment arguing collateral estoppel barred Spiotti’s statutory claims because the arbitrator already decided the underlying factual issues.
- The trial court denied the motion, relying on this court’s precedent in Genovese v. Gallo Wine Merchants, which held § 31-51bb prevents giving preclusive effect to arbitration findings in subsequent statutory or constitutional claims.
- The town appealed, arguing Genovese should be overruled in light of Conn. Gen. Stat. § 1-2z (plain meaning rule) and on the merits; the Supreme Court declined to overrule Genovese and affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Genovese should be overruled because § 1-2z bars reliance on legislative history in statutory interpretation | Genovese remains controlling; § 1-2z does not automatically overturn prior decisions | § 31-51bb is plain; Genovese relied on legislative history contrary to § 1-2z, so it should be overruled | Not overruled; § 1-2z does not erase prior precedent and stare decisis applies |
| Whether collateral estoppel bars Spiotti’s statutory/constitutional claims after adverse arbitration findings | Spiotti contends § 31-51bb allows her to pursue statutory/constitutional claims in court despite arbitration loss | Town contends arbitration findings preclude relitigation of the same factual issues | Court holds Genovese controls: arbitration findings are not preclusive for subsequent statutory/constitutional claims; plaintiff may litigate de novo |
| Whether the court must defer to the arbitration board’s factual findings | Spiotti: court should consider arbitration as evidence but decide de novo | Town: trial court should treat board findings as binding | Court: board decision may be admissible evidence but trial court must decide the statutory claims de novo; deference is not required |
| Whether stare decisis and legislative acquiescence justify retaining Genovese | Spiotti: legislature’s inaction and reliance interests support keeping Genovese | Town: earlier decision was wrong and should be corrected now | Court: stare decisis applies; no intervening developments or legislative correction justify overruling Genovese |
Key Cases Cited
- Genovese v. Gallo Wine Merchants, Inc., 226 Conn. 475 (1993) (held § 31-51bb prevents giving preclusive effect to arbitration findings in later statutory/constitutional actions)
- Alexander v. Gardner-Denver Co., 415 U.S. 36 (1974) (federal precedent allowing de novo judicial consideration of statutory discrimination claims after arbitration)
- McDonald v. West Branch, 466 U.S. 284 (1984) (referenced in legislative history rejecting preclusive effect of arbitral decisions for statutory claims)
- Hummel v. Marten Transport, Ltd., 282 Conn. 477 (2007) (held enactment of § 1-2z did not automatically overrule prior statutory-interpretation decisions)
- State v. Ray, 290 Conn. 602 (2009) (explains stare decisis and legislative acquiescence principles in statutory interpretation)