Paul West v. City of Hartford

CourtDistrict Court, D. Connecticut
DecidedDecember 19, 2025
Docket3:23-cv-01020
StatusUnknown

This text of Paul West v. City of Hartford (Paul West v. City of Hartford) 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.

Bluebook
Paul West v. City of Hartford, (D. Conn. 2025).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

PAUL WEST, ) 3:23-CV-01020 (SVN) Plaintiff, ) ) v. ) ) CITY OF HARTFORD, ) Defendant. ) December 19, 2025

RULING ON DEFENDANT’S MOTION FOR SUMMARY JUDGMENT

Sarala V. Nagala, United States District Judge. In this employment discrimination action, Plaintiff Paul West, who was formerly a lieutenant with the Hartford Police Department, alleges that Defendant City of Hartford discriminated against him on the basis of his race, color, disability, and sex; retaliated against him for his participation in protected activities; and intentionally inflicted emotional distress upon him in connection with, among other things, not selecting him for a promotion to the position of Captain. Defendant seeks summary judgment on all of Plaintiff’s claims, contending there are no genuine issues of material fact and that Defendant is entitled to judgment as a matter of law. Plaintiff opposes the motion. For the reasons described below, the Court agrees with Defendant, and GRANTS its motion for summary judgment. I. FACTUAL BACKGROUND Unless otherwise noted, the parties agree on the following facts. Where facts are undisputed, the Court cites only to Plaintiff’s Local Rule 56(a)2 Statement. A. Plaintiff’s Employment with the Hartford Police Department Plaintiff began his employment with the Hartford Police Department (the “Police Department”) in 2002 and moved up the ranks over time, serving as a dispatcher, a police officer, a sergeant, and, finally, a lieutenant. Pl.’s Local Rule 56(a)2 St., ECF No. 71 ¶¶ 1, 2, 4, 6. Plaintiff has obtained significant secondary education, including bachelor’s and master’s degrees and several certifications. See Pl.’s Add’l Mat. Facts, ECF No. 71, ¶ 12; Pl.’s Dep. Tr., ECF No. 71-1 at 9–10. In 2018, Plaintiff assisted a female colleague in the filing of a sexual harassment complaint.

ECF No. 71-1 at 44. According to his complaint, Plaintiff provided testimony in a deposition related to that matter on July 8, 2021. Compl., ECF No. 1 ¶ 11; see also ECF No. 71-1 at 45–46. In May of 2019, when Plaintiff was serving as a lieutenant, he suffered a brain injury. ECF No. 71 ¶ 7. He subsequently spent approximately four years on a full-incapacity medical leave of absence. Id. ¶ 8. According to Plaintiff, on or around October 1, 2021, Defendant’s Human Resources and Labor Relations department emailed Plaintiff a notice that Defendant “inten[ded] to remove [Plaintiff] from administrative leave with pay status and that his personal accruals [would] be used to cover his absences effectively September 29, 2020.” See ECF No. 1 ¶ 23; Pl.’s Add’l Mat. Facts ¶ 5.1 In his deposition, Plaintiff testified that he eventually was “taken off [administrative leave

status] for some time and they took my accruals and then I was placed back on,” after he successfully grieved the intent to remove him from administrative leave. ECF No. 71-1 at 94. B. Promotional Process for Captain Position On April 5, 2021, while Plaintiff was out on medical leave, the Police Department announced a vacancy in a Captain position. ECF No. 71 ¶ 9. The announcement provided details on salary, qualifications, and testing requirements, including a written examination scheduled for

1 Neither party has provided this email as part of its summary judgment submission. July 8, 2021, and an oral examination scheduled for July 29, 2021. Id. ¶ 10. For each of his prior promotions, Plaintiff had also sat for written and oral examinations. Id. ¶¶ 3, 5–6. On April 6, 2021, an individual named Dustin Rendock sent an email to officers on a listserv encouraging them to apply for the Captain promotional examination. Id. ¶ 15. Plaintiff denies that he was included on this email. Id.; Pl.’s Add’l Mat. Facts ¶ 2. Nevertheless, Plaintiff

submitted his application for the Captain position the same day. ECF No. 71 ¶ 16. On May 27, 2021, Defendant’s Principal Human Resources Analyst emailed Plaintiff to request that Plaintiff provide a note from his medical provider confirming he was medically cleared to take the promotional exam for the Captain position. Id. ¶ 17; Def.’s Ex. 5, ECF No. 68-1 at 62– 63. After a follow-up request, Plaintiff provided the doctor’s note on June 29, 2021. ECF No. 71 ¶¶ 19–20. The promotional exam was administered by a third-party testing agency that had administered three of the four prior promotional examinations Plaintiff had taken at the Police Department. Id. ¶ 21. Plaintiff successfully completed the written portion of the examination on

July 8, 2021, and was notified on July 20, 2021, that he would proceed to the oral examination phase. Id. ¶ 23. Plaintiff’s deposition in the sexual harassment matter occurred the same week as the written exam. ECF No. 71-1 at 45–46. Plaintiff took the oral examination on July 29, 2021. ECF No. 71 ¶ 27. The oral examination consisted of two parts: a scenario-based component, and an “in-basket” component involving simulation of real-life situations. Id. ¶¶ 24–26. Plaintiff was notified of his examination results on August 24, 2021. Id. ¶ 28. Plaintiff received a final score of 5.8000 on the oral scenario exercise, with the lowest score among candidates being 5.8000 and the highest 6.2800. Id. ¶ 30. Plaintiff received a score of 5.0600 on the in-basket exercise, with the lowest score being 2.9000 and the highest 5.1200. Id. ¶ 31. All examinees were informed they would be afforded the opportunity to review the recordings of their oral examination and, if they believed the assessors made a significant error in scoring, to request a secondary review of their results. Def’s Ex. 8, ECF No. 68-1 at 69. Plaintiff

requested and was granted a secondary review of his examination results. ECF No. 71 ¶¶ 34–35. Plaintiff’s score did not change after the secondary review. ECF No. 68-1 at 78–79. Plaintiff also sought additional information regarding his examination results, including the individual scores assigned by assessors, the demographic composition of the assessor panel, and whether assessors had access to candidates’ written examination scores. ECF No. 71 ¶ 36; ECF No. 71-1 at 76; Def.’s Ex. 10, ECF No. 68-1 at 83. Defendant in turn informed Plaintiff that no individual scores were assigned; that the score was determined through panel consensus after deliberation; and that the assessors were not provided with access to candidates’ written exam scores. ECF No. 71 ¶¶ 37, 39. Defendant did not provide Plaintiff with information about the

racial composition of the panel, asserting that it did not have access to such information, nor did the testing agency collect it. ECF No. 68-1 at 81–83; Pl.’s Add’l Mat. Facts ¶ 3. Under the Police Department’s policy, candidates are ranked according to their examination scores. ECF No. 71 ¶ 32. The names of the highest-scoring candidates were submitted to the Police Chief for interviews. Id. ¶ 33; see also Pl’s Dep. Tr. at 80–81. Plaintiff was not among the candidates selected for an interview and, ultimately, was not selected for the open Captain position. See ECF No. 71 ¶ 41. Plaintiff contends that no Black males were among the candidates selected for interviews or the Captain position. ECF No. 71 ¶ 42; Pl.’s Add’l Mat. Facts ¶ 4; ECF No. 1 ¶ 5. Plaintiff further states that for more than twenty years, no Black male has been promoted to Captain in the Police Department. Pl.’s Add’l Mat. Facts ¶ 1. Defendant, for its part, states that Jason Lee, one of the candidates selected for an interview and ultimately awarded a Captain position, is a Black male. ECF No. 71 ¶ 42. C. The Present Action Plaintiff’s complaint, which he filed pro se in June of 2023, alleges six counts. Five are

explicitly listed: one count each for race and color discrimination under Title VII of the Civil Rights Act of 1964, 42 U.S.C.

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Paul West v. City of Hartford, Counsel Stack Legal Research, https://law.counselstack.com/opinion/paul-west-v-city-of-hartford-ctd-2025.