NEW HAVEN (LN) — A Connecticut federal judge on Monday refused to grant summary judgment to the Town of Farmington in an ADA lawsuit brought by former Building Maintenance Foreman Brian Morin, ruling that genuine disputes of material fact on both a "regarded as" disability claim and an associational-discrimination claim must go to a jury.
Morin, who was hired in October 2015 and promoted to foreman in 2019, was diagnosed with a hernia in January 2022 after a work-related injury, underwent surgery, and returned to full duty on March 30, 2022. He was told on March 9, 2023, that his position was being eliminated. When he asked who was performing his job, the Town replied, according to the ruling, "We don't have to tell you."
U.S. District Judge Janet C. Hall, sitting in New Haven, held that a reasonable jury could conclude the Town regarded Morin as disabled under the ADA's "regarded as" prong. The Town argued that Town Manager Ms. Blonski — the ultimate decisionmaker — never perceived Morin as disabled. But Hall pointed to Staub v. Proctor Hospital, the 2011 Supreme Court decision holding that discriminatory animus from supervisors who feed into an adverse employment decision can be attributed to the employer. Morin's supervisors, Superintendent Jim Ruzbasan and Ms. Krajewski, were fully aware of his hernia, surgery, and subsequent lifting restrictions, according to the record.
Hall also held that the timing raised a genuine factual dispute. Morin produced evidence that Ruzbasan did not begin micromanaging him until after the hernia surgery, and that Ruzbasan "took Will [Young] away from [him], and would not allow me to have anyone assist me" — a change Morin testified occurred only post-surgery.
The Town offered a budget-driven justification: Town Manager Blonski faced a smaller-than-usual budget increase target from the Town Council and was advised that Morin's work could be outsourced more cheaply. Hall acknowledged the legitimate-reason showing but held that Morin raised enough pretext evidence to survive summary judgment. The Collective Bargaining Agreement required the Town to notify Morin of any open position for which he was qualified before hiring a new employee — a step the Town never took. Colleague William Young, who has no disability and no child with a disability, was promoted into the Capital and Highway Project Leader II position instead.
On the associational-discrimination count, Hall held that Ruzbasan, Ms. Krajewski, and Director of Public Works Mr. Arnold were all on notice no later than December 4, 2020, that Morin had a special-needs daughter, that he was her sole caregiver, and that he needed to arrange care before responding to after-hours calls. Morin also informed his supervisors that he had been late to work because he needed to ensure his daughter boarded her school bus at 6:45 a.m. Supervisors later gave Morin a low punctuality score in a job evaluation — an evaluation that fed into Blonski's decision to eliminate his position.
Hall also noted what happened when Morin tried to return. In May 2024, a Capital and Highway Project Leader I position opened; Morin obtained his CDL and notified the Town he wanted the job. The Town then told him it was no longer going to fill the position. The union reported back to Morin that the Town "just wanted to move forward, and they wanted to offer me a settlement, and we'll see what happens."
The case will proceed toward trial before Judge Hall in the District of Connecticut.