Eaddy v. City of Bridgeport
To prevail on a claim of discrimination on the basis of mental disability, a plaintiff may be required to prove that a perception exists that the plaintiff suffers from a mental disorder, as defined in the most recent edition of the American Psychiatric Association's "Diagnostic and Statistical Manual of Mental Disorders." In 2007, the defendant, the City of Bridgeport, hired the plaintiff employee, Arnetha Eaddy, as a police officer. The plaintiff alleged that on April 25, 2008 she argued with the officer who was her partner and then went to Hall-Brooke Hospital, where she remained about 10 days. The plaintiff's partner alleged that on April 25, 2008, the plaintiff removed her duty belt and unleashed a barrage of verbal complaints and obscenities about corruption that lasted about two hours. The plaintiff's partner claimed he was concerned whether the plaintiff would provide support in an emergency situation, because she was afraid to approach crowds and was scared to walk to her own motor vehicle without an escort. The chief of police ordered the plaintiff to undergo a fitness-for-duty evaluation. The psychiatrist opined it was highly likely the plaintiff was not fit for duty. The chief of police wrote to the Civil Service Commission that when the plaintiff was working in the field without a field training officer she appeared to be irrational and irate and was unable to cooperate with police officers. The chief of police indicated that the plaintiff's hospital records were not reviewed, because of HIPPA requirements. The Civil Service Commission voted to discharge. The plaintiff sued and alleged that she was discharged as a result of a perception of mental disability, in violation of Connecticut General Statutes §46a-51(20). The statute provides, "'Mental disability' refers to an individual who has a record of, or is regarded as having one or more mental disorders, as defined in the most recent edition of the American Psychiatric Association's 'Diagnostic and Statistical Manual of Mental Disorders.' " The court found that the plaintiff failed to establish any perception of mental disability existed, pursuant to C.G.S. §46a-51(20), and it granted judgment to the defendants.