Mayo v. Yale University, No. Cv 00-0440145 S (Feb. 7, 2002)

2002 Conn. Super. Ct. 1469, 31 Conn. L. Rptr. 334
CourtConnecticut Superior Court
DecidedFebruary 7, 2002
DocketNo. CV 00-0440145 S
StatusUnpublished

This text of 2002 Conn. Super. Ct. 1469 (Mayo v. Yale University, No. Cv 00-0440145 S (Feb. 7, 2002)) 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
Mayo v. Yale University, No. Cv 00-0440145 S (Feb. 7, 2002), 2002 Conn. Super. Ct. 1469, 31 Conn. L. Rptr. 334 (Colo. Ct. App. 2002).

Opinion

[EDITOR'S NOTE: This case is unpublished as indicated by the issuing court.]

MEMORANDUM OF DECISION ON DEFENDANTS' MOTION FOR SUMMARY JUDGMENT
INTRODUCTION

The complaint in this case contains nine counts. They allege, in essence, that the plaintiff was wrongfully discharged from her employment by the defendant Yale University ("Yale"), was discriminated against on the bases of age and sex and suffered emotional distress as a result of the negligent and intentional acts of Yale and of the defendant Robert Gifford.1 The defendants have moved for summary judgment on all counts on the ground that the plaintiff failed to exhaust administrative remedies available to her under Yale's employee handbook.

FACTS

The pleadings, the affidavits submitted in support of and in opposition to this motion and the stipulations of counsel establish the following facts:

1. The plaintiff had been employed by Yale's School of Medicine for eighteen years, when she was advised that her office was to be reorganized, her position was to be eliminated and she was to be discharged;

2. Before being so advised, the plaintiff had received from Yale an employee handbook ("handbook"), § 800 (all further section references are to the handbook) of which states in part:

In the normal course of working together, people may CT Page 1470 experience occasional misunderstandings or problems. The University is committed to giving employees fair and consistent treatment and providing a procedure for prompt consideration of their complaints. Employees are encouraged to use this procedure and may do so without fear of reprisal or prejudice.

3. The handbook goes on to state that an employee can complain about matters to his or her supervisor, and if the employee is unsatisfied with the supervisor's response, the employee can then file a grievance with Yale;

4. On September 17, 1998, the plaintiff met with a representative of Yale's Human Resources Department to discuss the upcoming elimination of her position;

5. Sometime in December 1998, the plaintiff was discharged by Yale;

6. On December 15, 1998, the plaintiff filed a grievance ("grievance") with Yale concerning the reorganization of her office and her discharge;

7. Section 802.2 calls for mediation of grievances, and if mediation is not successful, it goes on to provide:

The Human Resources administrator will notify the grievant and the respondent within two weeks after receipt of the grievance form either to outline the settlement reached or to indicate that no reconciliation appears feasible. This time limit and any subsequently cited are expected to be observed in order to ensure that the matters raised are addressed promptly; however, in some instances, additional time may be required for fact-finding because of the complexity of the case or the unavailability of parties or witnesses. Where a time limit is extended, the grievant and the respondent will be informed.

8. Section 803 authorizes employees who are dissatisfied with Yale's proposed resolution of a grievance to compel Yale to convene a panel of three persons (to be selected from a nine member Review Committee, each member of which is a Yale employee who is appointed to the Review Committee by the President of Yale) to hear the grievance; CT Page 1471

9. Yale did not communicate with the plaintiff concerning the grievance from the time it was filed on December 15, 1998 until March 8, 1999, when the plaintiff was advised that she could require Yale to convene a panel ("panel") to hear the grievance pursuant to § 803;

10. Yale did not provide to the plaintiff notice of any extensions of the timelines established by § 802.2;

11. Section 803.5 states: "The Panel's resolution shall be binding on the University";

12. The handbook does not state that the panel's resolution shall be binding on employees;

13. The handbook does not provide that an employee who is unsatisfied with a panel's decision may compel resolution of the dispute by binding arbitration by a neutral;

14. The handbook does not state that an employee's right to grieve is in lieu of the right to sue;

15. Section 801, entitled "Grievable Issues," provides, in relevant part:

Professional assessments and judgments of supervisors concerning such issues as performance evaluations, salary and grade classification determinations, and the staffing or organization of a department or allocation of its resources are not subject to review under this procedure, unless it is alleged that the professional assessment or judgment resulted from unlawful discrimination. A grievance panel may have to inquire into the procedure by which a professional judgment was made in reviewing a complaint, but the panel may not substitute its own judgment for that of the respondent.

DISCUSSION

"[S]ummary judgment shall be rendered forthwith if the pleadings, affidavits and any other proof submitted show that there is no genuine issue as to any material fact and that the moving party is entitled to judgment as a matter of law." (Internal quotation marks omitted.) Milesv. Foley, 253 Conn. 381, 385, 752 A.2d 503 (2000). "The party seeking summary judgment has the burden of showing the absence of any genuine issue [of] material facts which, under applicable principles of CT Page 1472 substantive law, entitle him to a judgment as a matter of law . . . and the party opposing such a motion must provide an evidentiary foundation to demonstrate the existence of a genuine issue of material fact." (Citation omitted; internal quotation marks omitted.) Id., 386.

The defendants have moved for summary judgment "because of the plaintiff's failure to exhaust the administrative remedies available to her." (Motion for Summary Judgment, p. 1.) Exhaustion of remedies is a doctrine which originally developed in the public sector, where, typically, a statute or regulation provides an administrative dispute resolution scheme ("ADR") as an alternative to suit, or which must be navigated as a condition precedent to bringing suit. See, e.g., General Statutes § 46a-82 (establishing procedure for filing discriminatory practice claims); General Statutes § 31-294c (establishing procedures for filing workers' compensation claims); General Statutes § 8-7 (establishing procedure for appealing zoning decisions). "It is a settled principle of administrative law that if an adequate administrative remedy exists, it must be exhausted before a [court will] obtain jurisdiction to act in the matter. . . . [W]here a statute has established a procedure to redress a particular wrong, a person must follow the specified remedy and may not institute a proceeding that might have been permissible in the absence of such a statutory procedure." (Citations omitted; internal quotation marks omitted.) Fish Unlimited v. Northeast Utilities ServiceCo., 254 Conn. 1, 11-12, 756 A.2d 262 (2000).

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Miles v. Foley
752 A.2d 503 (Supreme Court of Connecticut, 2000)
Fish Unlimited v. Northeast Utilities Service Co.
756 A.2d 262 (Supreme Court of Connecticut, 2000)
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611 A.2d 435 (Connecticut Appellate Court, 1992)
Scinto v. Sosin
721 A.2d 552 (Connecticut Appellate Court, 1998)

Cite This Page — Counsel Stack

Bluebook (online)
2002 Conn. Super. Ct. 1469, 31 Conn. L. Rptr. 334, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mayo-v-yale-university-no-cv-00-0440145-s-feb-7-2002-connsuperct-2002.