Brittell v Department of Correction (Connecticut 1998)

In Brittell v. Department of Correction, 247 Conn. 148 (1998), the plaintiff, a correction officer, alleged that the Department of Correction failed to remedy a hostile work environment caused by sexual harassment and rumors about her gender identity. After internal investigations failed to identify responsible individuals, the Department warned staff, provided support services, and offered the plaintiff a transfer, which she declined. The trial court found the employer’s response reasonable under the Connecticut Fair Employment Practices Act, and the Supreme Court affirmed. The Court held that the Department satisfied its duty to take prompt and appropriate remedial action, aligning state law with federal Title VII standards. It further concluded that the plaintiff was not constructively discharged, meaning the conditions were not severe enough that she was forced to quit.