Connecticut CHRO Administrative Discrimination Charge

CONNECTICUT CHRO DISCRIMINATION COMPLAINT (AFFIDAVIT)

TABLE OF CONTENTS

1. Filing Header
2. Complainant Information
3. Respondent Information
4. Cross-Filing Authorization
5. Protected Class(es)
6. Statutes Invoked
7. Date(s) of Discrimination and Timeliness
8. Statement of Particulars (Factual Allegations)
9. Comparators and Evidence
10. Harm Suffered
11. Relief Requested
12. Verification and Oath
13. Filing Instructions
14. Connecticut Practice Notes
15. Sources and References

1. FILING HEADER

STATE OF CONNECTICUT

COMMISSION ON HUMAN RIGHTS AND OPPORTUNITIES

450 Columbus Boulevard, Suite 2

Hartford, Connecticut 06103-1835

(860) 541-3400 | Toll-free: (800) 477-5737

Web: https://portal.ct.gov/CHRO

AFFIDAVIT OF ILLEGAL DISCRIMINATORY PRACTICE

CHRO Case No.: [________________________________] (assigned upon filing)

EEOC Charge No.: [________________________________] (if cross-filed)

2. COMPLAINANT INFORMATION

3. RESPONDENT INFORMATION

Additional Individual Respondents (e.g., supervisors, owners — if naming individually):

• [NAME, TITLE, ADDRESS]
• [NAME, TITLE, ADDRESS]

4. CROSS-FILING AUTHORIZATION

☐ I authorize the CHRO to cross-file this complaint with the U.S. Equal Employment Opportunity Commission (EEOC) pursuant to the CHRO/EEOC Worksharing Agreement, and to share information with the EEOC as necessary to process the complaint.

☐ I authorize the CHRO to cross-file with the U.S. Department of Housing and Urban Development (HUD) under the substantially equivalent agency designation (housing complaints only).

☐ I do NOT authorize cross-filing.

5. PROTECTED CLASS(ES)

I believe I have been discriminated against on the basis of (check all that apply):

☐ Race / Color [specify: ____________]

☐ Religious creed [specify: ____________]

☐ National origin / Ancestry [specify: ____________]

☐ Alienage / Citizenship status

☐ Sex / Gender [specify: ____________]

☐ Pregnancy or pregnancy-related condition

☐ Gender identity or expression [specify: ____________]

☐ Sexual orientation [specify: ____________]

☐ Marital status / Civil union status

☐ Age [specify date of birth: __/__/____]

☐ Physical disability (including blindness or deafness) [specify: ____________]

☐ Mental disability / Intellectual disability / Learning disability [specify: ____________]

☐ Status as a veteran

☐ Status as a victim of domestic violence

☐ Lawful source of income (housing/public accommodations contexts)

☐ Familial status (housing only)

☐ Genetic information

☐ Retaliation for opposition to discrimination or participation in protected activity

☐ Other protected class: [specify]

6. STATUTES INVOKED

The conduct violates the following statutes (check all that apply):

☐ Conn. Gen. Stat. § 46a-58 — Deprivation of rights (constitutional or statutory)

☐ Conn. Gen. Stat. § 46a-60(b)(1) — Discrimination in employment

☐ Conn. Gen. Stat. § 46a-60(b)(4) — Retaliation

☐ Conn. Gen. Stat. § 46a-60(b)(8) — Sexual harassment

☐ Conn. Gen. Stat. § 46a-64 — Public accommodations discrimination

☐ Conn. Gen. Stat. § 46a-64c — Housing discrimination

☐ Conn. Gen. Stat. § 46a-66 — Credit discrimination

☐ Conn. Gen. Stat. § 46a-70 — Equal employment in state agencies (state personnel)

☐ Title VII of the Civil Rights Act of 1964 (42 U.S.C. §§ 2000e et seq.)

☐ Americans with Disabilities Act (42 U.S.C. §§ 12101 et seq.)

☐ Age Discrimination in Employment Act (29 U.S.C. §§ 621 et seq.)

☐ Pregnancy Discrimination Act (Title VII)

☐ Pregnant Workers Fairness Act (42 U.S.C. § 2000gg et seq.)

☐ Genetic Information Nondiscrimination Act (42 U.S.C. §§ 2000ff et seq.)

☐ Equal Pay Act (29 U.S.C. § 206(d))

☐ Fair Housing Act (42 U.S.C. §§ 3601 et seq.)

☐ Other: [specify]

7. DATE(S) OF DISCRIMINATION AND TIMELINESS

7.1. Date of earliest discriminatory act: [__/__/____]

7.2. Date of most recent discriminatory act: [__/__/____]

7.3. ☐ Discrimination is continuing as of the date of this filing.

7.4. Timeliness Statement. This complaint is filed within 300 days of the most recent discriminatory act, in accordance with Conn. Gen. Stat. § 46a-82(f).

7.5. ☐ Complainant invokes the continuing violation doctrine to reach earlier discriminatory acts that are part of an ongoing pattern.

7.6. ☐ Complainant invokes equitable tolling because [describe basis — e.g., concealment, incapacity, agency error].

8. STATEMENT OF PARTICULARS (FACTUAL ALLEGATIONS)

8.1. I was hired by / engaged with / sought services from Respondent on [__/__/____] as [POSITION / CAPACITY].

8.2. At all relevant times, I was qualified for the position and performed my duties competently. [OR: I was qualified to receive the services / accommodations sought.]

8.3. Beginning on or about [__/__/____], I experienced the following discriminatory conduct:

• [Date / Description of Act 1 — who did what, where, when, said what]
• [Date / Description of Act 2]
• [Date / Description of Act 3]
• [Date / Description of Act 4]

8.4. The adverse action(s) taken against me include (check all that apply):

☐ Termination / Discharge ☐ Failure to hire ☐ Failure to promote

☐ Demotion ☐ Discipline / Write-up ☐ Suspension

☐ Reduction in pay or hours ☐ Denial of accommodation

☐ Hostile work environment / Harassment ☐ Constructive discharge

☐ Denial of public accommodation / service ☐ Eviction / Refusal to rent

☐ Retaliation ☐ Other: [specify]

8.5. I complained to [NAME / TITLE] on [__/__/____]. The response was: [describe].

8.6. [Continue with chronological narrative as needed.]

9. COMPARATORS AND EVIDENCE

9.1. Similarly situated comparators outside my protected class were treated more favorably. Specifically:

• [Name / Title / Protected status / Treatment received]
• [Name / Title / Protected status / Treatment received]

9.2. Direct evidence of discriminatory animus (statements, written communications, etc.):

• [Date / Speaker / Statement]
• [Date / Speaker / Statement]

9.3. Witnesses with relevant knowledge:

9.4. Documents in support (attached or available upon request):

☐ Employment contract / offer letter

☐ Performance reviews / evaluations

☐ Disciplinary records

☐ Pay stubs / W-2s

☐ Internal complaints / HR communications

☐ Termination letter / separation paperwork

☐ Emails / text messages / social-media posts

☐ Medical records (for disability or harassment claims)

☐ Witness statements

☐ Other: [specify]

10. HARM SUFFERED

I have suffered the following harm as a direct and proximate result of the discrimination:

• Lost wages and benefits of approximately $[AMOUNT] through the date of this complaint, with continuing losses;
• Lost employment opportunities including [describe];
• Emotional distress, humiliation, anxiety, depression, sleep disturbance, and other psychological harm;
• Damage to professional reputation and career trajectory;
• Out-of-pocket costs including [medical / job-search / relocation costs] of $[AMOUNT];
• [Other harm].

11. RELIEF REQUESTED

I request that the Commission grant the following relief:

☐ Cease-and-desist order prohibiting further discriminatory conduct;

☐ Reinstatement to my former position with full seniority and benefits;

☐ Back pay with interest from the date of the adverse action;

☐ Front pay in lieu of reinstatement where reinstatement is not feasible;

☐ Restoration of benefits (health insurance, retirement contributions, paid leave);

☐ Compensatory damages for emotional distress and out-of-pocket losses;

☐ Civil penalty under Conn. Gen. Stat. § 46a-89, where applicable;

☐ Affirmative action including anti-discrimination training, policy changes, and posting of CHRO notices;

☐ Expungement of disciplinary records and adverse personnel notations;

☐ Attorney's fees and costs under Conn. Gen. Stat. §§ 46a-104 and 52-251b (upon civil action);

☐ Public accommodations / housing relief including the requested service, accommodation, lease, or sale;

☐ Such other relief as the Commission deems just and proper.

12. VERIFICATION AND OATH

STATE OF CONNECTICUT

COUNTY OF [________________________________]

I, [COMPLAINANT FULL NAME], being first duly sworn, depose and say:

1. I am the Complainant in the foregoing Affidavit of Illegal Discriminatory Practice.

2. I have read the foregoing Affidavit and know the contents thereof.

3. The factual statements made herein are true and correct to the best of my knowledge, information, and belief, and as to those matters stated upon information and belief, I believe them to be true.

4. I understand that this Affidavit is made under oath and that knowingly making a false statement is punishable under Conn. Gen. Stat. § 53a-157b (false statement in the second degree) and § 53a-156 (perjury).

[________________________________]

[COMPLAINANT NAME], Complainant

Date: [__/__/____]

Sworn to and subscribed before me this [____] day of [_______________], 20[____].

[________________________________]

[Notary Public / Commissioner of the Superior Court / CHRO Intake Officer]

(My Commission Expires: [_______________])

13. FILING INSTRUCTIONS

A. Online Filing (Recommended).

1. Visit https://portal.ct.gov/CHRO and click "File a Discrimination Complaint."
2. Complete the online intake form.
3. The CHRO will contact the complainant to schedule an intake interview, after which the formal sworn complaint is finalized and signed.
4. NOTE: Submitting the online inquiry alone does not satisfy the 300-day deadline. The signed, sworn complaint must be filed within the 300-day window.

B. Mail Filing.
Mail the executed, notarized affidavit (this document) to:

Connecticut Commission on Human Rights and Opportunities
450 Columbus Boulevard, Suite 2
Hartford, CT 06103-1835

Use certified mail, return receipt requested, to document timely filing.

C. In-Person Filing.
The CHRO maintains regional offices in Hartford (450 Columbus Blvd.), Bridgeport, Waterbury, and Norwich. Contact the regional office for hours and intake-appointment availability.

D. Telephone Intake.
Call (860) 541-3400 (or toll-free (800) 477-5737) to begin intake. Telephone intake by itself does NOT preserve the 300-day deadline; a sworn written affidavit must be filed.

E. Specialized Lines.

• Housing complaints: (860) 541-3403
• Whistleblower retaliation: (860) 418-8770

14. CONNECTICUT PRACTICE NOTES

• 300-Day Deadline (CRITICAL). Current § 46a-82(f)(2) requires a complaint concerning an alleged act occurring on or after October 1, 2021, to be filed within 300 days. Section 46a-82(a) generally requires a written complaint under oath, while a housing complaint under § 46a-64c need not be notarized. The current statutory annotations describe the filing period as mandatory and subject to consent, waiver, or equitable tolling, not as a categorical subject-matter-jurisdictional bar.
• Employer Coverage. Current § 46a-51(10) defines an employer to include a person or entity with one or more employees.
• Protected Classes. Connecticut's protected-class list is among the broadest in the country, including sexual orientation, gender identity or expression, ancestry, status as a veteran, status as a victim of domestic violence, pregnancy-related conditions, and lawful source of income (in housing/public accommodations).
• Cross-Filing with EEOC. The CHRO/EEOC Worksharing Agreement permits dual filing. The first-receiving agency typically investigates. An EEOC right-to-sue does NOT authorize a state CFEPA suit — a separate CHRO Release of Jurisdiction (§ 46a-101) is required.
• Process After Filing.
  1. Case Assessment Review (Conn. Gen. Stat. § 46a-83) — initial screen for legal sufficiency. Complaints failing the screen are dismissed; complainant may request a Release of Jurisdiction to bring suit.
  2. Mandatory Mediation — CHRO offers early mediation.
  3. Investigation — CHRO investigator gathers evidence, interviews witnesses, and issues a Reasonable Cause / No Reasonable Cause finding.
  4. Public Hearing — if Reasonable Cause is found and conciliation fails, a contested hearing is held before a CHRO presiding officer.
  5. Release of Jurisdiction (§ 46a-101) — complainant may request release after 180 days for civil action; the action must be filed within 90 days of receipt of release and within two years after filing the CHRO complaint (§ 46a-102).
  • Damages on Civil Action. Conn. Gen. Stat. § 46a-104 authorizes legal and equitable relief including back pay, front pay, compensatory damages, and attorney's fees. Compensatory damages are NOT statutorily capped (unlike Title VII's 42 U.S.C. § 1981a tiered caps).
  • Punitive Damages. Current § 46a-104 expressly includes punitive damages; PA 19-16 added that remedy.
  • Statute of Limitations Interaction. The 300-day CHRO deadline is administrative; once a release issues, the complainant must file suit within 90 days of receipt (§ 46a-101(e)) and within two (2) years after filing the CHRO complaint (§ 46a-102).
  • Supplementing the Complaint. A complainant may amend or supplement the affidavit during the investigative phase. New incidents within the limitations period may be added.

15. SOURCES AND REFERENCES

• 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
• CHRO Contact Information — https://portal.ct.gov/chro/commission/commission/contact-us
• Conn. Gen. Stat. Title 46a, Chapter 814c — https://www.cga.ct.gov/current/pub/chap_814c.htm
• Conn. Gen. Stat. § 46a-82 (Filing) — https://www.cga.ct.gov/current/pub/chap_814c.htm#sec_46a-82
• Conn. Gen. Stat. § 46a-83 (Investigation, merit assessment, mediation) — https://www.cga.ct.gov/current/pub/chap_814c.htm#sec_46a-83
• 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-102 (civil-action filing limit) — https://www.cga.ct.gov/current/pub/chap_814c.htm#sec_46a-102
• CHRO/EEOC Worksharing Agreement — https://www.eeoc.gov/contract-eeccn130009-state-connecticut-commission-human-rights-and-opportunities-sections-c-j
• U.S. Equal Employment Opportunity Commission — https://www.eeoc.gov/
• Patino v. Birken Mfg. Co., 304 Conn. 679 (2012)
• Curry v. Allan S. Goodman, Inc., 286 Conn. 390 (2008)

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 use. Laws, citations, agency rules, and filing procedures change frequently; verify all authorities and contact the CHRO directly to confirm current intake procedures before filing.