A former Safelite employee in Connecticut alleging employment discrimination failed to file a timely complaint with the Connecticut Commission on Human Rights and Opportunities, according to a recent ruling. The U.S. Third Circuit of Appeals subsequently upheld the lower court’s decision in favor of the employer in late October.
Because Walters failed to follow proper Connecticut procedures, the Third Circuit ruled that the second question didn’t need to be addressed.
Nicholas Walters, a longtime Safelite employee, transferred from a store in Pennsylvania in 2015 to a store in Connecticut before being promoted to store manager later that year. He was terminated in 2017 after reported declines in the store’s performance and reports of “poor leadership skills” from his direct supervisor.
However, court documents note that employment discrimination claims in Connecticut first require that a claim be submitted to the Connecticut Commission on Human Rights and Opportunities. Walters did not file that Connecticut claim, according to the court’s opinion. New Jersey, on the other hand, does not have such a requirement. So Walters filed suit in 2018 in New Jersey seeking front pay, back pay and punitive damages.
“After amending his complaint once, Walters claimed that, among other things, Safelite retaliated against him for his objections to the company’s treatment of two employees in New Jersey – Greg Manning and Shelby Klein – both of whom later sued Safelite,” the court wrote.
Safelite was awarded summary judgment in the case after arguing that Walters failed to exhaust his claims as required by Connecticut law. Connecticut law was used as the jurisdictional venue in the case as it is the state in which Walters lived, worked and was terminated.
Furthermore, Safelite argued and the court affirmed, that there was no causal connection between Walters’ protected activity and termination. A successful appeal would have required Walters to convince the Third Circuit that the District Court erred on both accounts.
“Because both Walters’s employment and termination occurred in Connecticut, it would require rare circumstances to rebut the presumption that Connecticut substantive law applies,” the unpublished decision reads. “And this is not one of those rare situations. Safelite has stores in New Jersey, but it is not domiciled in that state.”
Because Walters failed to follow proper Connecticut procedures, the Third Circuit ruled that the second question didn’t need to be addressed.
“Connecticut employment law applies to Walters’s claims, and his suit fails because he did not timely file a complaint with the Connecticut Commission on Human Rights and Opportunities,” the judges wrote in the opinion. “It is therefore unnecessary to address whether Walters’s objections to Safelite’s treatment of Manning and Klein were too attenuated from his termination. Accordingly, we will affirm the judgment of the District Court.”
