Connecticut State Civil Rights Complaint

CONNECTICUT STATE CIVIL RIGHTS COMPLAINT

TABLE OF CONTENTS

1. Caption
2. Introduction
3. Parties
4. Jurisdiction and Venue
5. Administrative Exhaustion
6. Factual Allegations
7. Count I — Discrimination in Employment (Conn. Gen. Stat. § 46a-60)
8. Count II — Deprivation of Rights (Conn. Gen. Stat. § 46a-58)
9. Count III — Public Accommodations Discrimination (Conn. Gen. Stat. § 46a-64)
10. Count IV — Retaliation
11. Damages
12. Prayer for Relief
13. Demand for Trial by Jury
14. Signature and Service Blocks
15. Certificate of Service
16. Connecticut Practice Notes
17. Sources and References

1. CAPTION

STATE OF CONNECTICUT

SUPERIOR COURT

JUDICIAL DISTRICT OF [________________________________]

RETURN DATE: [_______________], 20[____]

DOCKET NO. [________________________________]

COMPLAINT

2. INTRODUCTION

1. This is a civil action under the Connecticut human rights statutes, Conn. Gen. Stat. §§ 46a-51 et seq., for discrimination, harassment, and retaliation on the basis of [PROTECTED CLASS — e.g., race, color, religious creed, age, sex, gender identity or expression, marital status, national origin, ancestry, sexual orientation, present or past history of mental disability, intellectual disability, learning disability, physical disability, status as a veteran, status as a victim of domestic violence].

2. Plaintiff seeks back pay, front pay, compensatory damages, punitive damages where authorized, declaratory and injunctive relief, attorney's fees, and costs pursuant to Conn. Gen. Stat. §§ 46a-100 and 46a-104.

3. PARTIES

3.1. Plaintiff [PLAINTIFF NAME] ("Plaintiff") is an adult individual who at all relevant times resided in [CITY/TOWN], [COUNTY] County, Connecticut.

3.2. Plaintiff is a member of the following protected class(es) under the Connecticut Fair Employment Practices Act and related statutes: [LIST PROTECTED CLASSES].

3.3. Defendant [EMPLOYER / OPERATOR NAME] ("Defendant") is a [corporation / limited liability company / sole proprietorship / municipal entity / state agency] organized and existing under the laws of [STATE], with a principal place of business at [ADDRESS].

3.4. At all relevant times, Defendant [employed three (3) or more persons / operated a place of public accommodation / was a state actor] within the meaning of Conn. Gen. Stat. § 46a-51(10) and was therefore subject to the Connecticut Fair Employment Practices Act.

3.5. [INDIVIDUAL SUPERVISOR / OFFICIAL DEFENDANT NAME] is named in [his/her/their] [individual / official] capacity as [TITLE] of [ENTITY].

4. JURISDICTION AND VENUE

4.1. This Court has subject-matter jurisdiction over this action pursuant to Conn. Gen. Stat. §§ 46a-100 (cause of action upon release from the Commission), 51-164s (general civil jurisdiction of the Superior Court), and 52-29 (declaratory judgment).

4.2. Venue is proper in this judicial district pursuant to Conn. Gen. Stat. § 46a-100 because the discriminatory practice was committed in this judicial district and/or because Defendant transacts business in this judicial district.

4.3. The amount in demand, exclusive of interest and costs, exceeds [$15,000.00 / $50,000.00 / $250,000.00], placing this matter within the jurisdictional thresholds of the Connecticut Superior Court.

5. ADMINISTRATIVE EXHAUSTION

5.1. On [__/__/____], within 300 days of the most recent discriminatory act as required by Conn. Gen. Stat. § 46a-82(f) (as amended by Public Act 19-93), Plaintiff filed a sworn Affidavit of Illegal Discriminatory Practice with the Connecticut Commission on Human Rights and Opportunities ("CHRO"), CHRO Case No. [____________].

5.2. Plaintiff cross-filed the charge with the U.S. Equal Employment Opportunity Commission ("EEOC") pursuant to the CHRO/EEOC Worksharing Agreement, EEOC Charge No. [____________].

5.3. On [__/__/____], the CHRO issued a Release of Jurisdiction pursuant to Conn. Gen. Stat. § 46a-101, authorizing Plaintiff to commence this civil action.

5.4. This Complaint is filed within ninety (90) days of Plaintiff's receipt of the Release of Jurisdiction, in accordance with Conn. Gen. Stat. § 46a-101(e), and within two (2) years of the date of the Release as further required by § 46a-102.

5.5. Plaintiff has therefore exhausted all administrative remedies prerequisite to bringing this action.

6. FACTUAL ALLEGATIONS

6.1. Plaintiff was hired by/became a customer of/sought services from Defendant on [__/__/____].

6.2. At all relevant times, Plaintiff [performed the essential functions of the position competently / met all qualifications / conducted himself/herself/themselves lawfully].

6.3. Beginning on or about [__/__/____], Defendant, through [supervisor / employee / agent name], engaged in the following discriminatory conduct:

• [Describe specific discriminatory acts — adverse employment actions, refusal of service, slurs, disparate treatment, denial of accommodation, etc.];
• [Describe pattern, frequency, and dates];
• [Identify comparators treated more favorably];
• [Identify any direct evidence — comments referencing protected class].

6.4. Plaintiff complained internally on [__/__/____] to [NAME / TITLE]. [Describe response or lack thereof.]

6.5. After Plaintiff's complaint, Defendant retaliated by [describe retaliation — termination, demotion, schedule change, hostile environment, etc.].

6.6. The discriminatory and retaliatory conduct was severe, pervasive, and motivated by Plaintiff's protected status.

6.7. As a direct and proximate result, Plaintiff has suffered [lost wages, lost benefits, emotional distress, humiliation, damage to reputation, etc.].

7. COUNT I — DISCRIMINATION IN EMPLOYMENT (Conn. Gen. Stat. § 46a-60)

7.1. Plaintiff realleges and incorporates Paragraphs 1 through 6.7.

7.2. Defendant is an "employer" within the meaning of Conn. Gen. Stat. § 46a-51(10), employing three (3) or more persons.

7.3. Conn. Gen. Stat. § 46a-60(b)(1) prohibits an employer from refusing to hire, discharging, or discriminating against any individual in compensation or in terms, conditions, or privileges of employment because of the individual's race, color, religious creed, age, sex, gender identity or expression, marital status, national origin, ancestry, present or past history of mental disability, intellectual disability, learning disability, physical disability, sexual orientation, status as a veteran, or status as a victim of domestic violence.

7.4. Defendant violated § 46a-60(b)(1) by [adverse action] against Plaintiff because of Plaintiff's [protected class].

7.5. Defendant's conduct constitutes a "discriminatory practice" within the meaning of Conn. Gen. Stat. § 46a-51(8) and entitles Plaintiff to relief under § 46a-104.

7.6. Defendant's conduct was willful, intentional, and undertaken with reckless indifference to Plaintiff's protected rights, supporting an award of punitive damages and attorney's fees.

8. COUNT II — DEPRIVATION OF RIGHTS (Conn. Gen. Stat. § 46a-58)

8.1. Plaintiff realleges and incorporates Paragraphs 1 through 7.6.

8.2. Conn. Gen. Stat. § 46a-58(a) provides that it shall be a discriminatory practice for any person to subject, or cause to be subjected, any other person to the deprivation of any rights, privileges or immunities secured or protected by the Constitution or laws of Connecticut or of the United States, on account of religion, national origin, alienage, color, race, sex, gender identity or expression, sexual orientation, blindness, mental disability, physical disability, or status as a veteran.

8.3. Defendant, acting [under color of state law / as a state actor / as a private actor], deprived Plaintiff of rights secured by the [Connecticut Constitution, Article First, §§ 1, 8, 14, 20 / Fourteenth Amendment to the U.S. Constitution / 42 U.S.C. § 1981 / other].

8.4. The deprivation was on account of Plaintiff's [protected status].

8.5. Pursuant to Conn. Gen. Stat. § 52-251b, the Court may award the prevailing party costs and a reasonable attorney's fee in any civil action arising out of a violation of § 46a-58.

9. COUNT III — PUBLIC ACCOMMODATIONS DISCRIMINATION (Conn. Gen. Stat. § 46a-64)

9.1. Plaintiff realleges and incorporates Paragraphs 1 through 8.5.

9.2. Defendant operates a "place of public accommodation, resort or amusement" within the meaning of Conn. Gen. Stat. § 46a-63(1), which includes any establishment that caters or offers its services, facilities, or goods to the general public.

9.3. Conn. Gen. Stat. § 46a-64(a)(1) makes it a discriminatory practice to deny any person within the jurisdiction of Connecticut full and equal accommodations in any place of public accommodation, resort, or amusement because of race, creed, color, national origin, ancestry, sex, gender identity or expression, marital status, age, lawful source of income, intellectual disability, mental disability, physical disability (including blindness or deafness), or status as a veteran.

9.4. Defendant denied Plaintiff full and equal accommodations because of Plaintiff's [protected class] by [describe denial — refusal of service, segregation, differential treatment, etc.] on [__/__/____] at [LOCATION].

9.5. Defendant's conduct violated Conn. Gen. Stat. § 46a-64 and entitles Plaintiff to relief under § 46a-104.

10. COUNT IV — RETALIATION

10.1. Plaintiff realleges and incorporates Paragraphs 1 through 9.5.

10.2. Conn. Gen. Stat. § 46a-60(b)(4) makes it a discriminatory practice for any employer to discharge, expel, or otherwise discriminate against any person because such person has opposed any discriminatory employment practice or because such person has filed a complaint or testified or assisted in any proceeding under § 46a-82, § 46a-83, or § 46a-84.

10.3. Plaintiff engaged in protected activity by [describe — internal complaint, CHRO charge, opposition to discrimination] on [__/__/____].

10.4. Defendant was aware of Plaintiff's protected activity.

10.5. Defendant subjected Plaintiff to a materially adverse action — [describe] — within a temporal proximity that supports a causal inference of retaliation.

10.6. Defendant's stated reasons for the adverse action are pretextual.

10.7. Defendant's retaliation violated § 46a-60(b)(4) and entitles Plaintiff to relief under § 46a-104.

11. DAMAGES

11.1. Economic Damages. Lost wages, lost benefits (including health insurance, retirement contributions, and bonuses), front pay, lost earning capacity, and out-of-pocket expenses, in an amount to be proven at trial but estimated to exceed $[AMOUNT].

11.2. Compensatory Damages. Emotional distress, humiliation, embarrassment, mental anguish, damage to reputation, loss of enjoyment of life, and consequential damages in an amount to be proven at trial.

11.3. Punitive Damages. Pursuant to Conn. Gen. Stat. § 46a-104 and applicable case law, Plaintiff seeks punitive damages for Defendant's willful, wanton, and reckless conduct.

11.4. Attorney's Fees and Costs. Pursuant to Conn. Gen. Stat. §§ 46a-104 and 52-251b.

11.5. Pre- and Post-Judgment Interest. Pursuant to Conn. Gen. Stat. § 37-3a.

12. PRAYER FOR RELIEF

WHEREFORE, Plaintiff respectfully demands judgment against Defendant as follows:

• A. Declaratory judgment that Defendant violated Conn. Gen. Stat. §§ 46a-58, 46a-60, and/or 46a-64;
• B. Permanent injunctive relief enjoining Defendant from further discrimination and retaliation, and ordering reinstatement, expungement of disciplinary records, and policy reforms as appropriate;
• C. Back pay with interest, front pay, and lost benefits;
• D. Compensatory damages in an amount to be determined at trial;
• E. Punitive damages to the extent permitted by law;
• F. Reasonable attorney's fees and costs pursuant to Conn. Gen. Stat. §§ 46a-104 and 52-251b;
• G. Pre-judgment and post-judgment interest;
• H. Such other and further relief as this Court deems just and equitable.

13. DEMAND FOR TRIAL BY JURY

Plaintiff demands a trial by jury on all issues so triable, pursuant to Conn. Const. art. I, § 19; Conn. Gen. Stat. § 52-215; and Conn. Practice Book § 14-10.

14. SIGNATURE AND SERVICE BLOCKS

Date: [__/__/____]

THE PLAINTIFF,

By: [________________________________]

[ATTORNEY NAME], Juris No. [######]

[LAW FIRM NAME]

[STREET ADDRESS]

[CITY, CT ZIP]

Telephone: [NUMBER]

Facsimile: [NUMBER]

Email: [EMAIL]

Counsel for Plaintiff

15. CERTIFICATE OF SERVICE

I hereby certify that on the [____] day of [_______________], 20[____], a true and correct copy of the foregoing Complaint was served upon Defendant by State Marshal pursuant to Conn. Gen. Stat. § 52-50, and/or by certified mail, return receipt requested, addressed as follows:

[DEFENDANT NAME AND SERVICE ADDRESS]

[________________________________]

[ATTORNEY NAME], Juris No. [######]

16. CONNECTICUT PRACTICE NOTES

• Administrative Exhaustion (CRITICAL). Discrimination claims under Title 46a generally must be filed first with the CHRO within 300 days. The complainant may seek a release of jurisdiction under § 46a-101 once 180 days have elapsed since filing or after case assessment review. Civil action must be filed within 90 days of release receipt. Failure to exhaust is jurisdictional and fatal.
• Protected Classes Under § 46a-60 (employment). Race, color, religious creed, age, sex (including pregnancy and pregnancy-related conditions per Public Act 21-32), gender identity or expression, sexual orientation, marital status, national origin, ancestry, intellectual/mental/learning/physical disability, status as a veteran, and status as a victim of domestic violence (added by Public Act 22-82).
• Employer Threshold. § 46a-60 applies to employers with three (3) or more employees — broader than Title VII's 15-employee threshold. As of October 1, 2017, the harassment-prevention provisions apply to employers of all sizes for sexual harassment.
• Public Act 19-93 ("Time's Up Act"). Effective Oct. 1, 2019, the CHRO filing deadline was expanded from 180 to 300 days, aligning with the federal EEOC standard.
• Damages. § 46a-104 authorizes legal and equitable relief, including back pay, front pay, compensatory damages, attorney's fees, and court costs. There is no statutory cap on compensatory damages (unlike Title VII's 42 U.S.C. § 1981a caps). Punitive damages under § 46a-104 in employment cases were construed narrowly in Tomick v. UPS, 324 Conn. 470 (2016); subsequent legislation has addressed remedy expansion. Verify currency before pleading.
• Attorney's Fees. Available under § 46a-104 (general remedy) and § 52-251b (specific to § 46a-58 violations). The amount of attorney's fees allowed is not contingent upon the amount of damages awarded.
• Relationship to Federal Claims. A CHRO release does not automatically authorize federal Title VII suit; conversely, an EEOC right-to-sue does not authorize state CFEPA suit. Counsel should obtain BOTH releases for parallel state and federal claims. Consider plenary 42 U.S.C. § 1983 or § 1981 claims for state-actor or race cases.
• Statute of Limitations on Civil Action. Action under § 46a-100 must be filed within 90 days of release receipt and not later than two (2) years from the date of the release per § 46a-102.
• Form of Pleading. Connecticut is a "fact pleading" jurisdiction (Conn. Practice Book § 10-1) — plead specific facts, not conclusions. Single-subject paragraphs, consecutively numbered.
• Return Date / Service. Civil actions in Connecticut commence by service of a Writ of Summons (Form JD-CV-1) and Complaint by State Marshal, with a Return Date set by counsel. The Complaint must be returned to court at least six days before the Return Date (Conn. Gen. Stat. § 52-46a).
• Apportionment / Multiple Defendants. Apportionment among joint tortfeasors does not apply to discrimination statutes; joint and several liability rules under Conn. Gen. Stat. § 52-572h govern only negligence claims.

17. SOURCES AND REFERENCES

• Conn. Gen. Stat. Title 46a (Human Rights), Chapter 814c — https://www.cga.ct.gov/current/pub/chap_814c.htm
• Conn. Gen. Stat. § 46a-58 (Deprivation of rights) — https://www.cga.ct.gov/current/pub/chap_814c.htm#sec_46a-58
• Conn. Gen. Stat. § 46a-60 (Discriminatory employment practices) — https://www.cga.ct.gov/current/pub/chap_814c.htm#sec_46a-60
• Conn. Gen. Stat. § 46a-64 (Public accommodations) — https://www.cga.ct.gov/current/pub/chap_814c.htm#sec_46a-64
• Conn. Gen. Stat. § 46a-100 (Civil action upon release) — https://www.cga.ct.gov/current/pub/chap_814c.htm#sec_46a-100
• Conn. Gen. Stat. § 46a-101 (Release of jurisdiction) — https://www.cga.ct.gov/current/pub/chap_814c.htm#sec_46a-101
• Conn. Gen. Stat. § 46a-104 (Civil action — relief) — https://www.cga.ct.gov/current/pub/chap_814c.htm#sec_46a-104
• Conn. Gen. Stat. § 52-251b (Attorney fees for § 46a-58) — https://www.cga.ct.gov/current/pub/chap_901.htm
• Public Act 19-93 ("Time's Up Act") — https://www.cga.ct.gov/2019/ACT/pa/pdf/2019PA-00093-R00SB-00003-PA.PDF
• Connecticut Commission on Human Rights and Opportunities — https://portal.ct.gov/CHRO
• CHRO Complaint Process — https://portal.ct.gov/chro/complaint-process/complaint-process/how-to-file-a-discrimination-complaint
• Connecticut Practice Book (Superior Court Rules) — https://www.jud.ct.gov/Publications/PracticeBook/PB.pdf
• Tomick v. United Parcel Service, Inc., 324 Conn. 470 (2016) (punitive damages under § 46a-104)
• Patino v. Birken Mfg. Co., 304 Conn. 679 (2012) (sexual orientation hostile environment)
• Curry v. Allan S. Goodman, Inc., 286 Conn. 390 (2008) (disability accommodation)

Disclaimer: This template is provided for informational purposes only and does not constitute legal advice. An attorney licensed in Connecticut must review and customize this document before filing. Laws, citations, and court rules change frequently; verify all authorities before use.