Janet C. Hall
How Judge Hall decides
Patterns drawn from this judge's own signed orders. Every observation links to the order it came from.
What persuades
On ADA/CFEPA disability claims she treats an open-ended, no-return-date leave request as fatal: an employer need not hold a position open indefinitely, so an employee who never supplies a return-to-work date is not a 'qualified individual with a disability' and cannot show discrimination, failure to accommodate, or retaliation.
“The specter of indefinite leave is not a reasonable accommodation for purposes of disability discrimination.”
Applies the Staub 'cat's-paw' theory to defeat summary judgment: a biased supervisor's input feeding a decisionmaker who did not personally know of the disability is enough to attribute animus to the employer, so 'regarded-as' and associational-discrimination claims survive even where the ultimate decisionmaker disclaims knowledge.
“Associational discrimination does not require that the ultimate decisionmaker know of the disability association; if someone within the chain of decision makers knew and was relied upon, the adverse employment decision is attributed to the employer.”
Procedural preferences
Willing to resolve liability on the clearest counts at summary judgment in a complex multi-count government enforcement case while expressly reserving damages: she grants partial summary judgment on the well-supported deceptive-advertising and per se statutory counts and holds that restitution and civil penalties require separate later briefing and a trial or hearing.
“If the plaintiffs desire monetary restitution or civil penalties, subsequent detailed briefing and a trial or hearing are required to determine the applicability and amount.”
Cautions
On a motion to dismiss she distinguishes abuse-of-process from defamation and declines to let the litigation privilege short-circuit the claim: filing an affidavit or seeking a prejudgment remedy 'primarily for an improper purpose' can state abuse of process even if the underlying motion was itself properly resolved, so framing such conduct as mere privileged litigation speech will not win dismissal.
“The litigation privilege does not, however, apply to abuse of process claims.”
Signed rulings
A grounded sample of orders signed by this judge, with the verbatim dispositive language.
“For the reasons discussed above, the court grants the City's Motion to Dismiss (Doc. Nos. 36, 44). The court dismisses the Amended Complaint without prejudice. ... Any such motion to amend shall be filed not later than twenty-one (21) days from the date of this Ruling. If no such motion is filed, the case will be dismissed with prejudice.”
“For the reasons stated above, the defendant's Motion for Partial Summary Judgment (Doc. No. 93) is denied.”
“For the reasons stated above, having concluded that Mr. Miller has adequately alleged claims of hostile work environment, constructive discharge, and employment discrimination under Counts One and Two of the Complaint, the court denies the Department's Motion to Dismiss (Doc. No. 17).”
“For the reasons discussed above, the defendant's Motion for Summary Judgment (Doc. No. 149) is granted. ... The Clerk is directed to enter judgment in favor of the defendant and close the case.”
“Because the court enters summary judgment for Leprino with respect to all five Counts of the Amended Complaint, the court deems the question of damages moot. Thus, the Motion to Preclude Mr. Kosowsky's testimony is denied as moot.”
“Thus, the court denies this Motion as moot.”
“For the reasons discussed above, the Motion for Summary Judgment (Doc. No. 39) is denied.”
Hall certified a question to the Connecticut Supreme Court concerning the defendant's motion to dismiss in a disability-discrimination suit against a state employer. The punitive-damages and sovereign-immunity argument turned on whether a 2019 amendment to Conn. Gen. Stat. 46a-104 waived sovereign immunity for CFEPA punitive damages. Rather than resolve the motion, she certified: 'Has the State of Connecticut waived sovereign immunity as to punitive damages in actions brought against the State pursuant to Conn. Gen. Stat. 46a-100, as delineated by 46a-104?' The order shows that where unsettled state law implicates state policy, she gives the state court the first word.
“For the foregoing reasons, Officers Teele and Speranza’s Second Motion for Summary Judgment (Doc. No. 105) is DENIED.”
“the plaintiff’s Motion for Judgment on the Pleadings (Doc. No. 17), Supplemental Motion for Judgment on the Pleadings (Doc. No. 19), Motion to Strike Answer (Doc. No. 18), and Motion to Strike Objection (Doc. No. 24) are DENIED.”
“Therefore, Webster Bank’s Motion for Summary Judgment (Doc. No. 32) is GRANTED, and the case is closed.”
“The Motion is granted insofar as it seeks to compel arbitration and a corresponding stay. The Motion is otherwise denied.”
“Mr. Cojom’s partial Motion for Default Judgment on his wage and hour claims is granted in part, and the court awards $214,293.22 in damages.”
“The Court grants the Mr. Cojom’s Motion for Attorneys’ Fees (Doc. No. 26), and awards $12,600 in attorneys’ fees and $758 in costs.”
“For the reasons stated above, plaintiffs’ Motion for Preliminary Injunction (Doc. 9) is denied.”
Put Judge Hall's record to work
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Opens in Ezel Pro. Every answer is grounded in Judge Hall's own signed orders and cites them.