Case law and Connecticut general statutes

Connecticut General Statutes CFEPA

The plaintiff, Donald Beason, brought a case against his employer, United Technologies Corporation. Beason is appealing from a judgment of a federal district court, the U.S. District Court for the District of Connecticut, that found in favor of his employer. The action is alleging a violation of the Connecticut Fair Employment Practices Act, which is appears beginning at Section 46a-51 of the Connecticut General Statutes, as well as a violation of the Americans with Disabilities Act.

Beason worked for United Technologies from 1979 until he was injured on the job in 1992. After the injury, he received workers' compensation benefits and he attempted to go back to work, but ended up staying on medical leave until he was eventually laid off because there was a lack of work early in 1993. In 1994, he received $35,000 to settle his workers' compensation claim. In 1995, he was recalled to work, but was sent for a medical evaluation first. The job he was being called back to work for required an intermediate level of exertion. The medical evaluation resulted in him not being allowed to return to work due to the 1992 injuries that impaired him from being able to perform the job.

Beason filed a complaint with the union he was a part of and went to arbitration where his claim was denied. His union grievance was pending while he filed a complaint in federal court. He alleged that United Technologies perceived him as disabled and discriminated against him, which was a violation of the CFEPA and the ADA. The district court found against Beason, and this case is an appeal from that decision.

The appeal only deals with the CFEPA because Beason contends that was improperly decided against him. The ADA is much narrower and is not pursued in the appeal. The district court used the ADA to interpret the CFEPA and Beason claims that was an error. The court in this case considers if the CFEPA definition of disability differs from the ADA's and if Beason has a cause of action.

To address these questions, the court interprets the Connecticut General Statutes that appear beginning at Section 46a-51. The court looks at other cases that demonstrate a willingness to use federal law, which would include the ADA, to interpret the state laws on anti-discrimination, and, if there was a difference between state and federal, the difference was probably for a reason. The definition of disability in the CFEPA is determined by the court as being broader than the ADA because the CFEPA does not require the person to be limited from performing major life activities in order to be considered disabled. To bolster this interpretation of the CFEPA, the court looks at cases that have applied the law, finding that they did not look to the limitation of life activities that is required in the narrower view espoused by the ADA. Consequently, the court rules that using the ADA to determine the CFEPA claim was erroneous.

With regards to the second question, the court looks at the language of the statute, where there is nothing to say that Beason can bring a claim for perceived physical disability discrimination. The court also looks at legislative history, which demonstrates that in the case of other anti-discriminatory statutes, there is language prohibiting discrimination based on a perception (as opposed to just discrimination based on something that is in fact there). The court views this as the legislature intending not to allow a claim for discrimination based on the perception that one is disabled and interprets the statute as such. Furthermore, the court finds no persuasive case law supporting Beason and rules against him, upholding the district court's decision.

The statutes that comprise the CFEPA, in particular Connecticut General Statute Section 46a-60, prohibit discriminatory employment practices. Part 1 of that statute is of relevance to Beason v. United Technologies because it explicitly prohibits an employer from refusing to employ or discharging someone because he or she has a physical or mental disability. In defining disability, the related statute at Section 46a-51 has the applicable definitions that are relevant to determining what is and is not a disability.