(a) No employer shall (1) discharge, or in any manner discriminate or retaliate against, any employee who in good faith makes a report pursuant to sections
17a-101a to
17a-101d, inclusive, and
17a-103, testifies or is about to testify in any proceeding involving child abuse or neglect, or (2) hinder or prevent, or attempt to hinder or prevent, any employee from making a report pursuant to sections
17a-101a to
17a-101d, inclusive, and
17a-103, or testifying in any proceeding involving child abuse or neglect. The Attorney General may bring an action in Superior Court against an employer who violates this subsection. The court may assess a civil penalty of not more than two thousand five hundred dollars and may order such other equitable relief as the court deems appropriate.
(b) Any person, institution or agency that (1) makes or does not make, in good faith, a report pursuant to sections 17a-101a to 17a-101d, inclusive, and 17a-103, or (2) provides, in good faith, professional medical intervention or assistance in any proceeding involving child abuse and neglect, including, but not limited to, (A) causing a photograph, x-ray or a physical custody examination to be made, (B) causing a child to be taken into emergency protective custody, (C) disclosing a medical record or other information pertinent to the proceeding, or (D) performing a medically relevant test, shall be immune from any liability, civil or criminal, which might otherwise arise from or be related to the actions taken pursuant to this subsection and shall have the same immunity with respect to any judicial proceeding which results from such report or actions, provided such person did not perpetrate or cause such abuse or neglect. The immunity from civil or criminal liability extends only to actions done pursuant to this subsection and does not extend to the malpractice of a medical professional that results in personal injury or death.
(c) Any person who is alleged to have knowingly made a false report of child abuse or neglect pursuant to sections 17a-101a to 17a-101d, inclusive, and 17a-103 shall be referred to the office of the Chief State's Attorney for purposes of a criminal investigation.
(d) Any person who knowingly makes a false report of child abuse or neglect pursuant to sections 17a-101a to 17a-101d, inclusive, and 17a-103 shall be fined not more than two thousand dollars or imprisoned not more than one year or both.
(P.A. 96-246, S. 6; P.A. 97-319, S. 12, 22; P.A. 12-82, S. 10; P.A. 13-53, S. 1; P.A. 18-57, S. 1; P.A. 24-41, S. 41.)
History: P.A. 97-319 amended Subsec. (b) by adding provision re immunity for persons who in good faith do not make a report, effective July 1, 1997; P.A. 12-82 added new Subsec. (c) re referral of persons who knowingly make a false report of child abuse or neglect to Office of the Chief State's Attorney and redesignated existing Subsec. (c) as Subsec. (d); P.A. 13-53 amended Subsec. (a) by designating existing provision re retaliation against employee who makes a report as Subdiv. (1) and adding Subdiv. (2) re hindering or preventing employees from making a report or testifying in a child abuse or neglect proceeding; P.A. 18-57 amended Subsec. (b) by deleting provision re person who in good faith does not make report re child abuse or neglect being immune from civil or criminal liability, designating existing provision re making report of child abuse or neglect as Subdiv. (1), adding Subdiv. (2) re immunity from civil or criminal liability when providing professional medical intervention or assistance in proceeding involving child abuse or neglect, replacing “be incurred or imposed” with “arise from or be related to the actions taken pursuant to this subsection” and by adding provision re immunity from civil or criminal liability only extends to action done pursuant to subsection and not to malpractice of a medical professional that results in personal injury or death, effective July 1, 2018, and applicable to any civil action pending on or filed on or after said date; P.A. 24-41 amended Subsec. (b) by replacing “which, in good faith, (1) makes a report pursuant to sections 17a-101a to 17a-101d, inclusive, and 17a-103, or (2) provides professional” with “that (1) makes or does not make, in good faith, a report pursuant to sections 17a-101a to 17a-101d, inclusive, and 17a-103, or (2) provides, in good faith, professional”, effective July 1, 2024.
Nothing in plain and unambiguous text of section suggests legislature intended to authorize private citizens to bring actions on their own behalf. 304 C. 483.
Subsec. (b):
Physician who performs medical examination at department's request to determine whether reasonable cause exists to suspect child abuse is entitled to immunity under Subsec. for claims arising from that determination, but not for diagnosis or treatment of any underlying injuries. 272 C. 410. Good faith immunity does not apply where trial court found that defendant acted with malice and without probable cause. 287 C. 397.
Section abrogates absolute immunity that the common law may have afforded by providing only qualified immunity to individuals who report abuse or neglect. 173 CA 539.
Notes of Decisions
Cited in
16
cases (
3 in the last 5 years), 2000–2025 · leading case:
Manifold v. Ragaglia, 862 A.2d 292 (Conn. 2004).
Manifold v. Ragaglia, 862 A.2d 292 (Conn. 2004).
· cites it 26× “The sole issue in this appeal is whether a physician who is not the initial reporter of suspected child abuse, but who performs a medical examination of a child at the request of the department of children and families (department) to determine whether reasonable cause exists to…”
Ward v. Greene, 839 A.2d 1259 (Conn. 2004).
· cites it 18× “) General Statutes § 17a-101e (b), as it incorporates Public Acts 1997, No.”
Perez-Dickson v. City of Bridgeport, 43 A.3d 69 (Conn. 2012).
· cites it 14× “" [5] General Statutes § 17a-101e provides in relevant part: "(a) No employer shall discharge, or in any manner discriminate or retaliate against, any employee who in good faith makes a report pursuant to sections 17a-101a to 17a-101d, inclusive, and 17a-103, testifies or is…”
Kruger v. Grauer, 164 A.3d 764 (Conn. App. Ct. 2017).
· cites it 26× “Additionally, the defendant asserts that the trial court erred in concluding that § 17a-101e abrogates the absolute immunity that she contends the common law affords her.”
Bhatia v. Debek, 948 A.2d 1009 (Conn. 2008).
· cites it 7× “1 On appeal, the defendant claims that the trial court improperly: (1) failed to address her claim that, because she acted in good faith, she is immune from liability for malicious prosecution, both under the common law and pursuant to General Statutes § 17a-101e (b); (2)…”
State v. Orr, 969 A.2d 750 (Conn. 2009).
· cites it 4× “Under General Statutes § 17a-101e (a), employers are prohibited from discriminating against a person who makes such a report or who "testifies or is about to testify in any proceeding involving child abuse or neglect.”
Manifold v. Ragaglia, 891 A.2d 106 (Conn. App. Ct. 2006).
· cites it 2× “10 In fact, in the present case, Creutz and Backus filed a motion for summary judgment based on a claim that they were statutorily immune pursuant to General Statutes § 17a-101e (b). See Manifold v.”
Noffsinger v. SSC Niantic Operating Co., 273 F. Supp. 3d 326 (D. Conn. 2017).
· cites it 2× “3d 69 (2012) (no private right of action against employer under Conn. Gen. Stat. § 17a-101e for retaliation against employee who reported child abuse where statute expressly provided for right of Attorney General to bring a court action if employer violated statute); Gerardi ,…”
State v. MARK R., 17 A.3d 1 (Conn. 2011).
· cites it 2× “General Statutes § 17a-101e (b) further provides that any person who, in good faith, makes a mandatory report of child abuse “shall be immune from any liability, civil or criminal, which might otherwise be incurred or imposed and shall have the same immunity with respect to any…”
Draper v. Westerfield, 181 S.W.3d 283 (Tenn. 2005).
“Conn. Gen.Stat. § 17a-101e(b) (2004) (“Any person, institution or agency which, in good faith, makes, or in good faith does not make, the report .”
S. v. Webb, 602 F. Supp. 2d 374 (D. Conn. 2009).
· cites it 2× “Conn. Gen. Stat. § 17a-101e(b). Connecticut law further provides that one who has “reasonable cause to suspect or believe that any child under the age of eighteen is in danger of being abused, or has been abused or neglected” may file a report with the Department of Children and…”
Vogel v. Maimonides Academy of W. Connecticut, Inc., 754 A.2d 824 (Conn. App. Ct. 2000).
“Any such person, institution or agency which, in good faith, makes the report required by this section shall be immune from any liability, civil or criminal, which might otherwise be incurred or imposed and shall have the same immunity with respect to any judicial proceeding…”
— Conn. Gen. Stat. § 17a-101e(b) — 4 cases
Kruger v. Grauer, 164 A.3d 764 (Conn. App. Ct. 2017).
“Additionally, the defendant asserts that the trial court erred in concluding that § 17a-101e abrogates the absolute immunity that she contends the common law affords her.”
Draper v. Westerfield, 181 S.W.3d 283 (Tenn. 2005).
“Conn. Gen.Stat. § 17a-101e(b) (2004) (“Any person, institution or agency which, in good faith, makes, or in good faith does not make, the report .”
S. v. Webb, 602 F. Supp. 2d 374 (D. Conn. 2009).
“Conn. Gen. Stat. § 17a-101e(b). Connecticut law further provides that one who has “reasonable cause to suspect or believe that any child under the age of eighteen is in danger of being abused, or has been abused or neglected” may file a report with the Department of Children and…”
— Conn. Gen. Stat. § 17a-101e(d) — 1 case
Kruger v. Grauer, 164 A.3d 764 (Conn. App. Ct. 2017).
“Additionally, the defendant asserts that the trial court erred in concluding that § 17a-101e abrogates the absolute immunity that she contends the common law affords her.”
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