Sullivan v. Board of Police Commissioners

491 A.2d 1096, 196 Conn. 208, 1985 Conn. LEXIS 767, 47 Fair Empl. Prac. Cas. (BNA) 538
CourtSupreme Court of Connecticut
DecidedMay 7, 1985
Docket11896
StatusPublished
Cited by115 cases

This text of 491 A.2d 1096 (Sullivan v. Board of Police Commissioners) is published on Counsel Stack Legal Research, covering Supreme Court of Connecticut primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Sullivan v. Board of Police Commissioners, 491 A.2d 1096, 196 Conn. 208, 1985 Conn. LEXIS 767, 47 Fair Empl. Prac. Cas. (BNA) 538 (Colo. 1985).

Opinion

Peters, C. J.

This case concerns the effect of federal and state statutes forbidding age discrimination on the mandatory retirement provisions of a local charter. The plaintiff, Frederick T. Sullivan, brought suit against the Waterbury board of police commissioners and the Waterbury retirement board, to enjoin the defendants from forcing him to retire at age sixty-five from his position as superintendent of the Waterbury police department. The trial court agreed with the plaintiff that his mandatory retirement would violate both the federal Age Discrimination in Employment Act (ADEA); 29 U.S.C. § 621 et seq.;1 and the Connecticut Fair Employment Practices Act (CFEPA); General Statutes § 46a-51 et seq.;2 and issued an injunction barring the plaintiffs involuntary retirement. The defendants have appealed, and the plaintiff has cross appealed claiming a right to recover attorney’s fees. We find error on the appeal and consequently dismiss the cross appeal as moot.

The relevant facts are undisputed. The plaintiff became superintendent of the Waterbury police depart[210]*210ment in 1968. On September 11, 1981, he wrote to Waterbury mayor Edward Bergin, chairman ex officio of the defendant board of police commissioners, announcing his intention to remain police superintendent after October 21, 1981, the date of his sixty-fifth birthday. The mayor replied that the plaintiff would have to vacate his position on October 21,1981, because § 2741 of the Waterbury charter makes retirement at the age of sixty-five mandatory for all police and fire personnel.3 This lawsuit ensued.

Immediately upon the filing of the plaintiffs lawsuit on October 16,1981, the trial court issued an ex parte temporary injunction, ordering the defendants to desist from attempting to remove the plaintiff from his position. After a full hearing, the trial court concluded: (1) that the ADEA was not unconstitutional in its application to state and local government employees; (2) that the defendants had failed to meet ADEA requirements for the establishment of a bona fide occupational qualification for discrimination based upon age; 29 U.S.C. § 623 (f) (l);4 and (3) that the defendants had also failed [211]*211to meet CFEPA requirements for the establishment of a bona fide occupational qualification for discrimination based upon age; General Statutes § 46a-60 (a) (l).5 Accordingly, the trial court granted the plaintiffs prayer for injunctive relief, barring his involuntary retirement “until a valid BFOQ (bona fide occupational qualification) is established excluding the plaintiff, or plaintiff exceeds the age protected by the statutes, plus taxable court costs but not attorney’s fees.” Throughout the pendency of these proceedings, the plaintiff has continued to serve as Waterbury police superintendent.

In this court, the defendants urge us to hold that they have established that being younger than sixty-five is a valid BFOQ for police personnel. They argue that the Waterbury charter provision is legal because it meets each of the two tests commonly applied to questions of age discrimination: the rational relation to public safety test and the two-tiered test permitting a general disqualification when either substantially all persons in the excluded class are incapable of performing the job or when it is highly impractical to make appropriate individual assessments of employability. They further claim that the trial court erred in failing to recognize that age is a per se BFOQ in this case because of special statutory provisions that apply to all employees engaged in police work. See 5 U.S.C. § 8335 (b);6 General Statutes § 46a-60 (b) (1) (C).7

The plaintiff, on the other hand, maintains that the trial court correctly concluded that state and federal [212]*212laws require an employer charged with age discrimination to demonstrate that a BFOQ is precisely tailored to the specific requirements of a particular employment situation. The plaintiff notes that in the context of discrimination based upon sex or physical disability, we have defined a BFOQ narrowly to permit such a defense only if “no member of the class excluded is physically capable of performing the tasks required by the job.” Evening Sentinel v. National Organization for Women, 168 Conn. 26, 36, 357 A.2d 498 (1975); Connecticut Institute for the Blind v. Commission on Human Rights & Opportunities, 176 Conn. 88, 95, 405 A.2d 618 (1978). He argues further that federal law, which applies both by its terms to his ADEA claim; see 29 U.S.C. §§ 623, 630, 631; EEOC v. Wyoming, 460 U.S. 226, 234-44, 103 S. Ct. 1054, 75 L. Ed. 2d 18 (1983); cf. Garcia v. San Antonio Metropolitan Transit Authority, 469 U.S. , 105 S. Ct. 1005, 83 L. Ed. 2d 1016 (1985); and as a persuasive resource for interpretation of our CFEPA; see Wroblewski v. Lexington Gardens, Inc., 188 Conn. 44, 53, 448 A.2d 801 (1982); Evening Sentinel v. National Organization for Women, supra, 36-37; imposes strict constraints upon the establishment of a BFOQ. See generally 29 C.F.R. § 1625.6 (a). The Supreme Court of the United States has recently held, in an age discrimination case under the ADEA, that a BFOQ must reflect the requirements of the particular position which the claimant seeks to fill or to retain rather than those of the industry as a whole. Trans World Airlines, Inc. v. Thurston, 469 U.S. , 105 S. Ct. 613, 622, 83 L. Ed. 2d 523 (1985). In addition, the equal employment opportunity commission (EEOC) has adopted the detailed standards for testing a BFOQ defense formulated in Usery v. Tamiami Trail Tours, Inc., 531 F.2d 224, 235-36 (5th Cir. 1976). See 29 C.F.R. § 1625.6 (b).

[213]*213Resolution of the merits of these conflicting arguments about the appropriate definition of a BFOQ for age discrimination claims would present an issue of first impression for this court. That issue cannot, however, be reached in this case because of its procedural posture. It is familiar learning that this court lacks the jurisdiction to decide the merits of a case over which the trial court lacked jurisdiction, and that jurisdictional matters must be addressed whether or not the parties have raised them in their pleadings. Laurel Park, Inc. v. Pac, 194 Conn. 677, 678-79 n.1, 485 A.2d 1272 (1984); Kulmacz v. Kulmacz, 177 Conn. 410, 412, 418 A.2d 76 (1979); LaReau v. Reincke, 158 Conn. 486, 494, 264 A.2d 576 (1969); Foss v. Foss, 105 Conn. 502, 512, 136 A. 98 (1927).

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Parlato v. East Haven
D. Connecticut, 2023
McVay v. Stefanou
D. Connecticut, 2021
Sempey v. Stamford Hospital
184 A.3d 761 (Connecticut Appellate Court, 2018)
Soules v. Connecticut
Second Circuit, 2018
Tomick v. United Parcel Service, Inc.
153 A.3d 615 (Supreme Court of Connecticut, 2016)
Sloan v. United Technologies Corp.
596 F. App'x 35 (Second Circuit, 2015)
Fried v. LVI Services, Inc..
557 F. App'x 61 (Second Circuit, 2014)
Hinde v. Specialized Education of Connecticut, Inc.
84 A.3d 895 (Connecticut Appellate Court, 2014)
Collins v. University of Bridgeport
781 F. Supp. 2d 59 (D. Connecticut, 2011)
Anderson v. Derby Board of Education
718 F. Supp. 2d 258 (D. Connecticut, 2010)
Dembinski v. Pfizer, Inc.
628 F. Supp. 2d 267 (D. Connecticut, 2009)
Martin v. Town of Westport
558 F. Supp. 2d 228 (D. Connecticut, 2008)
Pleau v. Centrix, Inc.
501 F. Supp. 2d 321 (D. Connecticut, 2007)
Olick v. Kearney
451 F. Supp. 2d 665 (E.D. Pennsylvania, 2006)
Desardouin v. United Parcel Service, Inc.
285 F. Supp. 2d 153 (D. Connecticut, 2003)
Okun v. Misiewicz, No. Cv 98 67084 S (Jul. 31, 2001)
2001 Conn. Super. Ct. 10351 (Connecticut Superior Court, 2001)
Brightly v. Abbott Terrace Health Center, No. Cv98-0148584s (Feb. 27, 2001)
2001 Conn. Super. Ct. 3029 (Connecticut Superior Court, 2001)
Stavena v. Sun International Hotels, Ltd., No. 116974 (Jun. 30, 2000)
2000 Conn. Super. Ct. 7974 (Connecticut Superior Court, 2000)

Cite This Page — Counsel Stack

Bluebook (online)
491 A.2d 1096, 196 Conn. 208, 1985 Conn. LEXIS 767, 47 Fair Empl. Prac. Cas. (BNA) 538, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sullivan-v-board-of-police-commissioners-conn-1985.