CGS § 46a-104. Civil action for discriminatory practice: Relief.

Cited. 232 C. 91. In light of Ames v. Commissioner of Motor Vehicles, 267 Conn. 524, and a close reading of text of section in relation to other related human rights statutes, section does not authorize an award of punitive damages in employment discrimination cases. 324 C. 470.

Cited. 44 CA 446. Court did not abuse its discretion by awarding plaintiff attorney's fees because jury found defendant created hostile work environment in violation of Sec. 46a-60 and awarded punitive damages. 117 CA 680. The legislature did not, either expressly or by force of a necessary implication, statutorily waive the state's sovereign immunity from liability for punitive damages under the fair employment practices act. 118 CA 65. Section does not explicitly authorize award of punitive damages, therefore plaintiff is not entitled to such relief under section; despite use of the phrase “including, but not limited to” to modify the phrase “legal and equitable relief”, section already explicitly authorizes award of attorney's fees and litigation costs, and awarding punitive damages would provide plaintiff with double recovery and alter the settled common-law rule limiting punitive damages to a single recovery of litigation expenses, and there is no clear intent by the legislature to provide multiple recovery of attorney's fees and litigation costs under section. 157 CA 312; judgment affirmed, see 324 C. 470.