Can Employers Win Summary Judgment In State Court? Yes, but…
Connecticut Employment Law Blog | Blog
August 17, 2026
I have often said that getting summary judgment in an employment discrimination case in Connecticut state court is hard.
State judges are typically reluctant to grant such motions, and the conventional wisdom among practitioners is that it takes extraordinary facts to get there.
Which is what makes a recent decision worth noting. The court granted the defendants’ motion for summary judgment in its entirety, dismissing claims for race discrimination, disability discrimination, workers’ compensation retaliation, and violations of the Palliative Use of Marijuana Act (PUMA).
The facts of the case are pretty straightforward: a former police officer brought a four-count complaint alleging that the town, its police chief, and another official discriminated against him on the basis of race, disability, and his medical marijuana patient status, and retaliated against him for filing a workers’ compensation claim.
On the race discrimination claim, the court said that the only evidence of racial animus was two comments made by unnamed employees in 2017. The plaintiff was not terminated until March 2020, more than two and a half years later. The court found this gap in time to be fatal to the claims. Indeed, at oral argument, plaintiff’s counsel conceded that the two comments were the only evidence of racial discrimination.
On the disability discrimination claim, the court found that the plaintiff could not perform the essential functions of his job as a patrol officer. His own doctor stated that he was unable to return to full duty because he could not lift or move 200 pounds, a requirement listed in the job description. The plaintiff had been on medical leave for more than a year. The court also dismissed the failure-to-hire claims for two administrative positions, finding no evidence that the individuals who screened applications were aware of the plaintiff’s disability.
On the workers’ compensation retaliation claim, the court applied the temporal proximity standard from another case which held that three months or more between the protected activity and the adverse action is insufficient, standing alone, to create an inference of causation. The plaintiff’s workers’ compensation claim was filed in 2014. His termination occurred in 2020. That six-year gap was just not enough to establish the claim.
PUMA claims are rarely seen in court. But even here, the court found no evidence that the plaintiff was terminated “solely” because of his status as a qualifying patient, which is the standard the statute requires.
I have written before about the difficulty of winning summary judgment in employment cases in Connecticut state court. Judges are generally inclined to let a jury sort things out, and the conventional wisdom is that it’s for two reasons: credibility determinations and inferences from circumstantial evidence are typically jury questions. But this case shows that summary judgment can be won when the plaintiff’s evidence simply does not connect to the adverse employment action.
For employers, cases like this have a few built in lessons.
First, document the timeline. The temporal gap between the alleged discriminatory comments and the termination was the dispositive fact on the race claim. When adverse employment actions are separated by years from any evidence of bias, that gap provides strong support for summary judgment. Employers who can demonstrate a clean record between the alleged discriminatory conduct and the employment decision are in a much stronger position.
Second, job descriptions are your friends; use them and update them. The disability claim failed because the employer had a written job description with specific physical requirements and a doctor’s note confirming the plaintiff could not meet them. That is exactly how it should work. Keep job descriptions current, ensure they accurately reflect essential functions, and use them when making fitness-for-duty determinations.
And lastly, even with the victory, no doubt the employer spent a considerable sum defending against the claims. While the employer here can claim a victory, it most certainly came at a price. Knowing that the cost of such cases is a cost of doing business is not anything to write home about, but it’s something that should just be taken into account.