WRONGFUL TERMINATION DEMAND LETTER

Connecticut Law

[ATTORNEY/FIRM LETTERHEAD]

[Firm Name]
[Address Line 1]
[City, State ZIP]
Tel: [Phone Number]
Fax: [Fax Number]
[Attorney Email]
[Connecticut Bar Registration No.]

VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED
AND VIA EMAIL TO: [recipient_email]

[Date]

[Employer Contact Name]
[Title]
[Company Legal Name]
[Company Address]
[City, State ZIP]

Re: Wrongful Termination of [Client Full Name]
Former Position: [Job Title]
Dates of Employment: [Start Date] through [Termination Date]
CONFIDENTIAL SETTLEMENT COMMUNICATION - CONN. CODE EVID. Section 4-8

Dear [Mr./Ms./Mx. Last Name]:

This firm represents [Client Full Name] ("our client") regarding [his/her/their] wrongful termination from employment with [Company Legal Name] ("[Company Short Name]") on [Termination Date]. Please direct all further communications to our office.

We write to demand immediate action to remedy the unlawful termination and to resolve this matter short of litigation. [Company Short Name]'s termination of our client violates Connecticut law and exposes the Company to substantial liability.

I. CONNECTICUT EMPLOYMENT LAW FRAMEWORK

A. At-Will Employment and Its Exceptions

Connecticut follows the employment-at-will doctrine but recognizes broad exceptions. See Sheets v. Teddy's Frosted Foods, Inc., 179 Conn. 471, 427 A.2d 385 (1980).

1. Public Policy Exception

Connecticut broadly recognizes the public policy exception to at-will employment. See Sheets v. Teddy's Frosted Foods, Inc., 179 Conn. 471, 427 A.2d 385 (1980) (landmark decision recognizing public policy tort).

Protected activities under Connecticut public policy include:
- Refusing to violate a law or regulation
- Reporting employer's illegal activities (whistleblowing)
- Exercising statutory rights (workers' compensation, jury duty, wage claims)
- Performing important public obligations

2. Implied Contract Exception

Connecticut recognizes implied employment contracts based on employer handbooks, policies, and oral representations. See Finley v. Aetna Life & Cas. Co., 202 Conn. 190, 520 A.2d 208 (1987).

3. Covenant of Good Faith and Fair Dealing

Connecticut recognizes an implied covenant of good faith and fair dealing in employment contracts. See Magnan v. Anaconda Indus., Inc., 193 Conn. 558, 479 A.2d 781 (1984).

4. Statutory Protections

Connecticut provides extensive statutory protections:
- Connecticut Fair Employment Practices Act (CFEPA): Conn. Gen. Stat. Section 46a-60 et seq.
- Whistleblower Protection: Conn. Gen. Stat. Section 31-51m
- Free Speech Protection: Conn. Gen. Stat. Section 31-51q
- Workers' Compensation Retaliation: Conn. Gen. Stat. Section 31-290a
- Family and Medical Leave: Conn. Gen. Stat. Section 31-51kk et seq.
- Jury Service Protection: Conn. Gen. Stat. Section 51-247a

B. Connecticut Administrative Procedures

Connecticut Commission on Human Rights and Opportunities (CHRO):
- File within 180 days of alleged discriminatory act
- Dual-filing with EEOC available
- Right to request release to pursue private action after 180 days

II. FACTUAL BACKGROUND

A. Employment History

[Client Full Name] was employed by [Company Short Name] from [Start Date] through [Termination Date] as a [Job Title] in [City], Connecticut.

Employment Summary:

Our client was a dedicated employee with an excellent performance record:
- [Describe positive performance history]
- [Describe promotions, raises, commendations]
- [Describe any relevant achievements]

B. The Protected Activity / Triggering Event

On or about [Date], our client [describe protected activity]:

• Reported illegal or unethical conduct in violation of law or regulation
• Refused to participate in illegal activity
• Filed a workers' compensation claim under Conn. Gen. Stat. Section 31-290a
• Exercised rights under the Connecticut Family and Medical Leave Act
• Engaged in protected speech under Conn. Gen. Stat. Section 31-51q
• [Other protected activity]

C. The Wrongful Termination

On [Termination Date], [Company Short Name] terminated our client, purportedly for [stated reason]. This stated reason is pretextual, as evidenced by:

1. Temporal proximity: The termination occurred just [X days/weeks] after the protected activity
2. Prior positive treatment: Our client had [no prior discipline / positive reviews / recent promotion]
3. Disparate treatment: Similarly situated employees who did not engage in protected activity were [not terminated / treated more favorably]
4. Shifting explanations: [Describe any inconsistent reasons given]
5. Direct evidence: [Describe any statements indicating true motive]

III. LEGAL CLAIMS UNDER CONNECTICUT LAW

A. Wrongful Discharge in Violation of Public Policy

Under Sheets v. Teddy's Frosted Foods, Inc., 179 Conn. 471, 427 A.2d 385 (1980), Connecticut recognizes a cause of action for wrongful discharge when termination violates an important public policy.

Elements of Claim:
1. Employer-employee relationship
2. Termination of employment
3. Termination violated an important public policy
4. Damages resulting from termination

Public Policy Violated: [Company Short Name] terminated our client for [describe conduct that violated public policy], which violates [cite specific statute, regulation, or constitutional provision].

See also Morris v. Hartford Courant Co., 200 Conn. 676, 513 A.2d 66 (1986); Parsons v. United Technologies Corp., 243 Conn. 66, 700 A.2d 655 (1997).

B. Whistleblower Retaliation (Conn. Gen. Stat. Section 31-51m)

Connecticut's whistleblower statute provides:

"No employer shall discharge, discipline or otherwise penalize any employee because the employee... reports, verbally or in writing, a violation or a suspected violation of any state or federal law or regulation..."

Our client reported [describe report of illegal activity] on [Date]. [Company Short Name] terminated our client in retaliation for this protected whistleblowing activity.

Remedies under Section 31-51m:
- Reinstatement to former position
- Back pay with interest
- Restoration of benefits and seniority
- Reasonable attorney's fees
- Court costs

C. Retaliatory Discharge - Workers' Compensation (Conn. Gen. Stat. Section 31-290a)

[If applicable:] Connecticut General Statutes Section 31-290a provides that no employer shall discharge an employee for filing a workers' compensation claim.

Our client filed a workers' compensation claim on [Date] for [injury]. [Company Short Name] terminated our client in retaliation for exercising this statutory right.

D. Violation of Connecticut Fair Employment Practices Act (CFEPA)

[If applicable:] [Company Short Name]'s termination of our client constitutes unlawful [discrimination/retaliation] under Conn. Gen. Stat. Section 46a-60, based on [protected characteristic/protected activity].

E. Breach of Implied Contract

[Company Short Name]'s Employee Handbook and representations created an implied contract limiting termination to "just cause" and/or requiring specific progressive discipline procedures.

Evidence of implied contract:
- Employee Handbook provisions stating [quote relevant language]
- Personnel policies requiring [describe procedures]
- Oral representations by [Name] that [describe assurances]

See Finley v. Aetna Life & Cas. Co., 202 Conn. 190, 520 A.2d 208 (1987).

IV. DAMAGES

A. Economic Damages

1. Back Pay

2. Lost Benefits

3. Front Pay

B. Compensatory Damages (Non-Economic)

Our client has suffered severe emotional distress:
- [Describe anxiety, depression, humiliation]
- [Describe impact on health and relationships]
- [Describe medical treatment sought]

Emotional distress damages: $[Amount]

C. Punitive Damages

[Company Short Name]'s conduct was willful, malicious, and in reckless disregard of our client's rights, warranting punitive damages under Connecticut law.

See Venturi v. Savitt, Inc., 191 Conn. 588, 468 A.2d 933 (1983) (punitive damages available for wanton, reckless, or malicious conduct).

D. Attorney's Fees

Under Conn. Gen. Stat. Sections 31-51m (whistleblower) and 31-290a (workers' comp retaliation), our client is entitled to reasonable attorney's fees.

Estimated fees through trial: $[Amount]

E. Summary of Damages

V. SETTLEMENT DEMAND

We demand that [Company Short Name] pay $[Settlement Demand Amount] in full settlement of all claims.

Additional Terms:
- Neutral reference (dates and position only)
- No contest to unemployment benefits
- Expungement of personnel file
- Mutual non-disparagement
- Confidentiality (terms to be negotiated)

VI. RESPONSE DEADLINE

Please respond within fourteen (14) calendar days, no later than [Response Deadline Date].

If we do not receive a satisfactory response, we are authorized to file suit in the [Connecticut Superior Court, Judicial District of [District] / United States District Court for the District of Connecticut] without further notice.

Causes of Action:
1. Wrongful Discharge in Violation of Public Policy
2. Violation of Conn. Gen. Stat. Section 31-51m (Whistleblower Protection)
3. Violation of Conn. Gen. Stat. Section 31-290a (Workers' Compensation Retaliation)
4. Breach of Implied Contract
5. [CFEPA / Other claims as applicable]

VII. DOCUMENT PRESERVATION

Immediately implement a litigation hold to preserve all relevant documents and ESI regarding our client's employment, performance, and termination.

VIII. CONFIDENTIALITY

This letter is protected by Connecticut Code of Evidence Section 4-8 and constitutes a confidential settlement communication.

Sincerely,

[Attorney Name]
[Title]
[Firm Name]
[Connecticut Bar Registration No.]

Enclosures:
- Authorization to Represent

cc: [Client Name]
[File]

CONNECTICUT-SPECIFIC PRACTICE NOTES (Do Not Include in Final Letter)

Key Connecticut Considerations

• Connecticut recognizes broad public policy exception under Sheets v. Teddy's Frosted Foods
• Whistleblower statute (Section 31-51m) provides strong protections and fee-shifting
• CHRO complaint required for discrimination claims - 180-day deadline
• Connecticut is a deferral state for EEOC purposes - 300-day EEOC deadline
• Free speech protection (Section 31-51q) is unique to Connecticut
• Implied contract claims viable with proper handbook language
• No punitive damage caps in most employment cases

Venue Options

• Connecticut Superior Court (general jurisdiction)
• Federal Court (if federal claims or diversity jurisdiction over $75,000)

Statute of Limitations

Key Connecticut Cases

• Sheets v. Teddy's Frosted Foods, Inc., 179 Conn. 471, 427 A.2d 385 (1980)
• Parsons v. United Technologies Corp., 243 Conn. 66, 700 A.2d 655 (1997)
• Morris v. Hartford Courant Co., 200 Conn. 676, 513 A.2d 66 (1986)
• Finley v. Aetna Life & Cas. Co., 202 Conn. 190, 520 A.2d 208 (1987)
• Magnan v. Anaconda Indus., Inc., 193 Conn. 558, 479 A.2d 781 (1984)