Dawn Merritt v. State of Connecticut Workers’ Compensation Commission

CourtDistrict Court, D. Connecticut
DecidedNovember 6, 2025
Docket3:24-cv-00798
StatusUnknown

This text of Dawn Merritt v. State of Connecticut Workers’ Compensation Commission (Dawn Merritt v. State of Connecticut Workers’ Compensation Commission) is published on Counsel Stack Legal Research, covering District Court, D. Connecticut primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Dawn Merritt v. State of Connecticut Workers’ Compensation Commission, (D. Conn. 2025).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

-------------------------------- x DAWN MERRITT, : : Plaintiff, : : v. : : Civil No. 3:24-cv-798 (AWT) STATE OF CONNECTICUT WORKERS’ : COMPENSATION COMMISSION, : : Defendant. : : : -------------------------------- x

RULING ON MOTION TO DISMISS Plaintiff Dawn Merritt (“Merritt”) has filed an Amended Complaint against her former employer, the State of Connecticut Workers’ Compensation Commission (the “Commission”), claiming violations of Title VII of the Civil Rights Act of 1964, as amended, 42 U.S.C. § 2000e, et seq. (“Title VII”), and the Connecticut Fair Employment Practices Act (“CFEPA”), Conn. Gen. Stat. § 46a-60. In Count One, the plaintiff claims that the Commission subjected her to a hostile work environment and disparate treatment because of her race in violation of Title VII. See Am. Compl. (ECF No. 30) at 13-15 (¶¶ 36-46).1 In Count

1 The Amended Complaint contains several paragraphs that have the same numbers. Compare Am. Compl. at 13-14 (¶¶ 36-46) with id. at 15-17 (¶¶ 36-46). Therefore, at times the court cites to pages within the Amended Complaint and puts the paragraphs on that page to which it refers in parentheses. Two, the plaintiff brings the same claims under CFEPA. See id. at 15 (¶¶ 47-48). In Count Three, the plaintiff claims that the Commission subjected her to a hostile work environment and

disparate treatment because of her sex in violation of Title VII. See id. at 15-17 (¶¶ 36-46). In Count Four, the plaintiff brings the same claims under CFEPA. See id. at 17 (¶¶ 47-48). In Count Five, the plaintiff claims that the Commission subjected her to a hostile work environment and disparate treatment because of her age in violation of CFEPA. See id. at 17-19 (¶¶ 33-44). The Commission moves to dismiss the Amended Complaint under Federal Rule of Civil Procedure 12(b)(6) for failure to state a claim upon which relief may be granted. For the reasons set forth below, the defendant’s motion to dismiss is being granted. I. FACTUAL ALLEGATIONS

The Amended Complaint alleges the following circumstances. “Ms. Merritt is a member of a protected class, as a woman of mixed race and light Black skin.” Am. Compl. ¶ 7. “Ms. Merritt is also above the age of 40.” Id. “Ms. Merritt began working for WCC on or about June 30, 2022, as an Office Assistant or Receptionist for the Chairman, Stephen Morelli.” Id. ¶ 8. “The office reception area where Ms. Merritt worked was an open office environment where all conversations could be easily overheard by other employees and members of the public, Id. “From the outset of Ms. Merritt’s employment, and continuing to the end of her employment, Ms. Merritt was

subjected to discriminatory treatment based on her race/color, age, and sex.” Id. ¶ 9. “Specifically, in the open reception area of the WCC office, where other employees and members of the public could overhear, Joanne Crawford, the administrative educational coordinator, who was a supervisory employee over Ms. Merritt, asked Ms. Merritt about her age, which made her feel uncomfortable and singled out due to her age.” Id. ¶ 10. “Stephanie Parrott, a trainer who was also a supervisory employee over Ms. Merritt, and Debra Prenergast, a secretary who was also supervisory over Ms. Merritt because of her stature, tenure, and experience, overheard Ms. Crawford ask Ms. Merritt about her age.” Id. ¶ 11. “After Ms. Merritt responded with her

age, Ms. Parrott remarked, ‘I can’t believe you’re that age!’” Id. ¶ 12. “This comment embarrassed Ms. Merritt and made her feel ashamed about her appearance, as if she had to justify her looks given her age.” Id. “Because Ms. Parrott, Ms. Crawford, and Ms. Prenergast were senior employees at WCC, each had an independent duty to report this incident, but failed to take any action after it occurred.” Id. “On another occasion, Ms. Prenergast asked Ms. Merritt, ‘Why are you dressing like that?’” Id. ¶ 13. “This comment was made in reference to Ms. Merritt’s contemporary, professional attire.” Id. “Ms. Prenergast’s remark implied that Ms. Merritt’s clothing choices were inappropriate due to her age, race and

gender as an older woman of color.” Id. “The comment made Ms. Merritt feel self-conscious and unwelcome in the workplace.” Id. “Kailey Townsend, Ms. Merritt’s adult daughter, would occasionally visit Ms. Merritt at the office.” Id. ¶ 14. “Eric Rentz, a safety supervisor who had supervisory authority over Ms. Merritt, made a discriminatory comment to Ms. Merritt about the dark complexion of Ms. Townsend, in contrast to Ms. Merritt’s lighter-skinned complexion.” Id. ¶ 15. “Without any context or prior conversation about Ms. Merritt’s personal life, Mr. Rentz asked Ms. Merritt in a dismissive tone, ‘how many baby daddies do you have?’” Id. ¶ 16. “This racially and gender- charged stereotype deeply offended Ms. Merritt, as it made

assumptions about her family structure and implied promiscuity based on harmful racial and gender stereotypes about Black women.” Id. “The comment was particularly hurtful because it was made in earshot of other employees and members of the public in the reception area and because of Mr. Rentz’s position and authority as a supervisor in the office.” Id. “As a supervisor in the office, Mr. Rentz had a duty under WCC policy to report this incident, but did nothing.” Id. “The ‘baby daddies’ stereotype is commonly used to demean Black women by implying promiscuity and unstable family structures.” Id. ¶ 16A. “Ms. Merritt formally complained about this conduct to Ms. Marie Gallo-Hall, chief law clerk of WCC.” Id. ¶ 17. “Ms. Gallo-

Hall was the designated person to receive such complaints according to WCC policy.” Id. “Ms. Merritt provided the details of each incident and expressed that she felt discriminated against and harassed based on her race, sex, and age.” Id. “Ms. Gallo-Hall assured Ms. Merritt that the complaints would be investigated.” Id. “Instead of taking effective remedial action, Ms. Gallo-Hall simply responded by forwarding the WCC EEO policies to the WCC staff listserv by email without any context or explanation.” Id. “On or about September 14, 2022, in the open reception area of the WCC office where other employees and members of the public could overhear, Ms. Ligia Pena, health and safety

coordinator, a person with supervisory authority over Ms. Merritt, called herself ‘a White Cracker.’” Id. ¶ 18. “This racially-charged slur was particularly offensive given Ms. Merritt’s mixed-race background and light skin tone.” Id. “This remark, made in the presence of Ms. Townsend, came after a conversation of hair products for curly hair.” Id. ¶ 19. “This further ties the comment to Ms. Merritt’s race.” Id. “Ms. Pena, showing no remorse or recognition of the offensive nature of her comment, then said to Ms. Merritt, ‘You can never be one-hundred percent White trash like me.’” Id. ¶ 20. “These comments made Ms. Merritt feel degraded, othered, and uncomfortable in her workplace due to her race.” Id. 20. “The

remarks reinforced harmful racial stereotypes. Id. “Despite having a duty to report this incident to HR as a supervisory employee, Ms. Pena failed to report the incident.” Id. “About one week later, Ms. Merritt reported the ‘White Cracker’ and ‘white trash’ remarks to Ms. Gallo-Hall, the designated person to receive such complaints.” Id. ¶ 21. “Ms. Merritt explained how these comments were racially offensive and created a hostile work environment.” Id. “At around the same time that Ms.

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