Duncan v. Junior Achievement, Inc., No. Cv96 033 58 78 S (Jan. 27, 2000)

2000 Conn. Super. Ct. 1121
CourtConnecticut Superior Court
DecidedJanuary 27, 2000
DocketNo. CV96 033 58 78 S
StatusUnpublished

This text of 2000 Conn. Super. Ct. 1121 (Duncan v. Junior Achievement, Inc., No. Cv96 033 58 78 S (Jan. 27, 2000)) is published on Counsel Stack Legal Research, covering Connecticut Superior Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Duncan v. Junior Achievement, Inc., No. Cv96 033 58 78 S (Jan. 27, 2000), 2000 Conn. Super. Ct. 1121 (Colo. Ct. App. 2000).

Opinion

[EDITOR'S NOTE: This case is unpublished as indicated by the issuing court.]

MEMORANDUM OF DECISION RE: MOTION TO STRIKE (DOCKET ENTRY NO. 174)
Before the court is the motion to strike of the defendant Junior Achievement of Western Connecticut, Inc. The complaint alleges the following facts. On or about December 2, 1991, the plaintiff, John Duncan, was hired by the board of directors of Junior Achievement of Western Connecticut, Inc. (Western) as its president. Western's office is located in Bridgeport, Connecticut. Junior Achievement, Inc. (National) is the parent company and national headquarters of Western. National's office is located in Colorado Springs, Colorado. On January 17, 1995, the plaintiff was discharged by Western. Bryan Heubner, the Chairman of the Board of Directors of Western, informed the plaintiff of his termination. The plaintiff's termination letter was placed on People's Bank letterhead.

On January 5, 1999, the plaintiff filed a twenty-seven count amended complaint against Western and National, alleging, inter alia, unauthorized disclosure, breach of implied contract, unjust enrichment, emotional distress, and violations of the Connecticut Unfair Trade Practices Act (CUTPA). On May 14, 1999, Western moved to strike counts three, six, sixteen, twenty, twenty-two, and twenty-five of the plaintiff's amended complaint for failure CT Page 1122 to state claims upon which relief can be granted. Western has submitted a memorandum in support of its motion and the plaintiff has filed a memorandum in opposition thereto.

"The purpose of a motion to strike is to contest . . . the legal sufficiency of the allegations of any complaint . . . to state a claim upon which relief can be granted." (Internal quotation marks omitted.) Peter-Michael, Inc. v. Sea ShellAssociates, 244 Conn. 269, 270, 709 A.2d 558 (1998). The court "must take as true the facts alleged in the plaintiff's complaint and must construe the complaint in the manner most favorable to sustaining its legal sufficiency. . . . If facts provable in the complaint would support a cause of action, the motion to strike must be denied." (Citations omitted; internal quotation marks omitted.) Id., 270-71. "A motion to strike is properly granted if the complaint alleges mere conclusions of law that are unsupported by the facts alleged." Novametrix Medical Systems,Inc. v. BOC Group, Inc., 224 Conn. 210, 215, 618 A.2d 25 (1992). "Moreover, . . . [w]hat is necessarily implied [in an allegation] need not be expressly alleged." Pamela B. v. Ment, 244 Conn. 296,308, 709 A.2d 1089 (1998).

A. Unauthorized Disclosure
In support of its motion to strike count three claiming unauthorized disclosure, Western argues that a private right of action does not exist under the Personnel Files Act, General Statutes § 31-128a et seq. Nevertheless, Western argues that even if a private right of action exists, the plaintiff fails to identify a violation of the statute. Notably, Western argues that the plaintiff fails to state what part of the termination letter, which is the subject of the plaintiff's claim, constitutes confidential personnel information. Moreover, Western argues that the allegations are legally insufficient because the plaintiff has not identified to whom disclosure was made, how he was harmed by the alleged disclosure, or what the remedy is. The plaintiff, in response, argues that a private right of action is inherent in General Statutes § 31-128f because the statute prohibits employers from disclosing to third parties an employee's personnel file information without authorization. In addition, the plaintiff argues that the termination letter, which is incorporated into his complaint, provides sufficient facts as to whom disclosure was made.

General Statutes § 31-128f provides in relevant part: "No CT Page 1123 individually identifiable information contained in the personnel file or medical records of any employee shall be disclosed by an employer to any person or entity not employed by or affiliated with the employer without the written authorization of such employee except where the information is limited to the verification of dates of employment and the employee's title or position and wage or salary. . . ." A private right of action does not exist under the Personnel Files Act, General Statutes § 31-128a et seq. See Turzer v. Connecticut National Bank, Superior Court, judicial district of Fairfield at Bridgeport, Docket No. 279671 (October 10, 1991, Spear, J.); Dais v. LaidlawTransit, Inc., Superior Court, judicial district of Stamford/Norwalk at Stamford, Docket No. 146079 (March 29, 1996, Ryan, J.).

In Turzer v. Connecticut National Bank, the defendant moved to strike the plaintiff's unauthorized disclosure claim arguing that General Statutes § 31-128g does not provide for a private cause of action. The court, citing the legislative intent of the statute, held that claims arising under § 32-128g can be dealt with by the labor commissioner, pursuant to his powers under General Statutes 31-2(a).1 See Turzer v. Connecticut NationalBank, supra, Superior Court, Docket No. 279671. Specifically, the court stated: "Though the legislative intent militates in favor of the Labor Commissioner's handling potential violations of31-128g, the issue remains as to whether this court should entertain this claim notwithstanding that intent. The doctrine of primary jurisdiction militates against the court taking jurisdiction. . . ."

"It is well established that resort to the administrative process is generally a prerequisite to involving the jurisdiction of a court. . . . [P]rimary jurisdiction situations arise in cases where a plaintiff, in the absence of pending administrative proceedings, involves the original jurisdiction of a court to decide the merits of a controversy. . . . The purpose of the doctrine is to foster an orderly process of administrative adjudication and judicial review in which a reviewing court will have the benefit of an agency's findings and conclusions. . . . Ordinarily, a court should not act upon subject matter that is peculiarly within the agency's specialized field without giving the agency an opportunity to apply its expertise, for otherwise parties who are subject to the agency's continuous regulation may become the victims of uncoordinated and conflicting requirements. . . . The doctrine of primary jurisdiction militates in favor CT Page 1124 of this claim going first to the Labor Commissioner." (Citations omitted; internal quotation marks omitted.) Turzer v. ConnecticutNational Bank, supra, Superior Court, Docket No. 279671. In Daisv. Laidlaw Transit, Inc., the defendant also moved to strike the plaintiff's unauthorized disclosure claim, under §

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Bluebook (online)
2000 Conn. Super. Ct. 1121, Counsel Stack Legal Research, https://law.counselstack.com/opinion/duncan-v-junior-achievement-inc-no-cv96-033-58-78-s-jan-27-2000-connsuperct-2000.