Eccleston v. Waterbury

************************************************ The “officially released” date that appears near the beginning of an opinion is the date the opinion will be published in the Connecticut Law Journal or the date it is released as a slip opinion. The operative date for the beginning of all time periods for the filing of postopinion motions and petitions for certification is the “officially released” date appearing in the opinion. All opinions are subject to modification and technical correction prior to official publication in the Connecti- cut Law Journal and subsequently in the Connecticut Reports or Connecticut Appellate Reports. In the event of discrepancies between the advance release version of an opinion and the version appearing in the Connecticut Law Journal and subsequently in the Connecticut Reports or Connecticut Appellate Reports, the latest version is to be considered authoritative. The syllabus and procedural history accompanying an opinion that appear in the Connecticut Law Journal and subsequently in the Connecticut Reports or Connecticut Appellate Reports are copyrighted by the Secretary of the State, State of Connecticut, and may not be reproduced or distributed without the express written permission of the Commission on Official Legal Publications, Judicial Branch, State of Connecticut. ************************************************  Eccleston v. Waterbury THOMAS ECCLESTON v. CITY OF WATERBURY (AC 48841) Cradle, C. J., and Suarez and Seeley, Js.* Syllabus The plaintiff, who had formerly been employed as a firefighter by the defen- dant city, appealed from the trial court’s judgment of dismissal pursuant to the rule of practice (§ 15-8) for failure to make out a prima facie case. He claimed, inter alia, that the court improperly concluded that he had failed to make out a prima facie case of wrongful termination of employment in violation of the statute (§ 21a-408 et seq.) governing the palliative use of marijuana. Held: This court declined to review the plaintiff’s claim that the trial court improp- erly concluded that he had failed to make out a prima facie case of wrong- ful termination of employment under § 21a-408 et seq., as that claim was inadequately briefed, the plaintiff having asserted limited arguments that were bereft of legal analysis and either patently incorrect or conclusory and failed to adequately address the dispositive bases for the court’s conclusion. This court declined to review the plaintiff’s claim that the trial court improp- erly concluded that he had failed to make out a prima facie case of defama- tion, as that claim was inadequately briefed, the plaintiff having failed to challenge the court’s conclusion or to set forth any evidence in support of his prima facie case. Argued March 17—officially released September 22, 2026 Procedural History Action to recover damages for, inter alia, the allegedly wrongful termination of the plaintiff’s employment under the Palliative Use of Marijuana Act, and for other relief, brought to the Superior Court in the judicial dis- trict of Waterbury and tried to the court, Massicotte, J.; thereafter, the court, Massicotte, J., granted the defendant’s motion to dismiss and rendered judgment of dismissal, from which the plaintiff appealed to this court. Affirmed. * The listing of judges reflects their seniority status on this court as of the date of oral argument.  Eccleston v. Waterbury Norman A. Pattis, with whom, on the brief, was Tho- mas Eccleston, self-represented, the appellant (plaintiff). Joseph A. Mengacci, for the appellee (defendant). Opinion CRADLE, C. J. In this action, the plaintiff, Thomas Eccleston, alleged wrongful termination of his employ- ment in violation of the Palliative Use of Marijuana Act (PUMA), General Statutes § 21a-408 et seq., and defa- mation of character against the defendant, the city of Waterbury, his former employer. The plaintiff appeals from the judgment of dismissal, rendered by the trial court pursuant to Practice Book § 15-81 for failure to make out a prima facie case. On appeal, the plaintiff claims that the court improperly concluded that he had failed to make out a prima facie case of (1) wrongful termination in violation of General Statutes § 21a-408p (b) (3)2 and (2) defamation. We affirm the judgment of the trial court. The record reveals the following facts, taking the plain- tiff’s evidence as true and interpreting it in the light 1 Practice Book § 15-8 provides in relevant part: “If, on the trial of any issue of fact in a civil matter tried to the court, the plaintiff has produced evidence and rested, a defendant may move for judgment of dismissal, and the judicial authority may grant such motion if the plaintiff has failed to make out a prima facie case. . . .” 2 General Statutes § 21a-408p (b) (3) provides: “No employer may refuse to hire a person or may discharge, penalize or threaten an employee solely on the basis of such person’s or employee’s status as a qualifying patient or caregiver under sections 21a-408 to 21a-408m, inclusive. Nothing in this subdivision shall restrict an employer’s ability to prohibit the use of intoxicating substances during work hours or restrict an employer’s ability to discipline an employee for being under the influence of intoxi- cating substances during work hours.” Although PUMA has been amended by the legislature since the events underlying this appeal; see, e.g., Public Acts, Spec. Sess., June 2021, No. 21-1, § 77; those amendments have no bearing on the merits of this appeal. In the interest of simplicity, we refer to the current revision of the act.  Eccleston v. Waterbury most favorable to him,3 and procedural history that are relevant to our resolution of this appeal. The plaintiff was employed by the defendant as a firefighter with the Waterbury Fire Department (fire department) in 1995. In November 2015, the plaintiff entered into a “last chance agreement” with the defendant in order to avoid termination of his employment for conduct unrelated to the present case. The last chance agreement provided, inter alia, that the plaintiff “may be subject to immedi- ate termination . . . [i]f [he] tests positive for alcohol (at the level of 0.04 or above) or a controlled substance.” (Internal quotation marks omitted.) In September 2017, the plaintiff was diagnosed with post-traumatic stress disorder. The diagnosing physician recommended medical marijuana as a treatment. The plaintiff thereafter sought opinions from two additional physicians, including Leela A. Panoor,4 who ultimately prescribed him medical marijuana. On March 6, 2018, the plaintiff obtained his medical marijuana card from the Department of Consumer Protection. On March 20, 2018, the plaintiff was called for a ran- dom drug test, and the result was positive for marijuana. When the medical review officer informed the plaintiff that he had tested positive for marijuana use, the plain- tiff did not dispute the results and instead informed the officer that he was a medical marijuana patient. The plaintiff thereafter provided the defendant with his medical marijuana card.5 At the recommendation of the defendant’s department of human resources, the plaintiff was placed on light duty status and directed to obtain “a note from his physician that he was fit for duty as a 3 “In evaluating [the trial court’s decision on] a motion to dismiss, [t]he evidence offered by the plaintiff is to be taken as true and interpreted in the light most favorable to [the plaintiff], and every reasonable inference is to be drawn in [the plaintiff’s] favor.” (Internal quotation marks omitted.) Chen v. Hopkins School, Inc., 148 Conn. App. 543, 548, 86 A.3d 482 (2014). 4 The plaintiff did not call Panoor to testify at trial. 5 At trial, the parties stipulated that the plaintiff provided a valid medical marijuana card to the defendant after he tested positive for marijuana but before his employment was terminated.  Eccleston v. Waterbury firefighter with his current card.” In a fitness for duty certification dated March 30, 2018, Panoor certified that the plaintiff was fit for full duty with no restrictions. On April 23, 2018, the plaintiff received a letter from David J. Martin, then chief of the fire department, informing the plaintiff that his employment was ter- minated (termination letter). The termination letter summarized five reasons for the plaintiff’s termina- tion, namely, violating the last chance agreement, two workplace drug testing policies, and the substance abuse testing policy of the collective bargaining agreement between the city and the Waterbury firefighters associa- tion, Local L1339 (union), as well as “[e]ngaging in the use of marijuana such that it has endangered the health and wellbeing of others.” The plaintiff was never accused of being under the influence of or consuming marijuana while at work. The termination letter was courtesy cop- ied to Scott Morgan, the defendant’s human resources director; Linda Whibey, the defendant’s corporation counsel; and John Schultz, the president of the union. On April 27, 2018, soon after the plaintiff’s employ- ment was terminated, an article was published in the Waterbury Republican-American newspaper discuss- ing the termination of the plaintiff’s and another fire- fighter’s employment.6 The article contained, inter alia, several quotations that the author attributed to Martin and summarized certain findings made at a disciplinary hearing that had been held regarding the plaintiff. On April 22, 2021, the plaintiff filed a two count com- plaint against the defendant. In the operative complaint, which was filed on May 17, 2022, the plaintiff asserted claims of (1) wrongful termination of employment in 6 Although the plaintiff submitted two articles as exhibits at trial, the court noted that the exhibits were simply “different versions of the same article,” and, therefore, it treated them as one article. The articles have different titles and authors, however, the articles’ texts are largely identical. Accordingly, for the purposes of simplicity, like the trial court, we treat the articles as one article.  Eccleston v. Waterbury violation of § 21a-408p (b) (3)7 and (2) defamation of character on the basis of statements made by Martin to the newspaper and in the termination letter.8 On February 20, 2025, the trial court, Massicotte, J., commenced a bench trial at which the plaintiff testified and called only Martin as a witness. The plaintiff also introduced several exhibits in support of his claims, namely, two separate portions of the collective bar- gaining agreement governing his employment with the defendant, the defendant’s drug-free workplace policy, the fire department’s random substance abuse testing policy, a 2018 investigation report regarding the plain- tiff’s positive marijuana test, the termination letter, the article, and the plaintiff’s fitness for duty evaluation conducted by Panoor. The defendant’s counsel, during 7 The plaintiff originally brought these state court claims in federal court, along with claims alleging, against both the defendant and Water- bury mayor Neil O’Leary, “discriminatory discharge, failure to provide reasonable accommodations as required by the [Americans with Disabili- ties Act, 42 U.S.C. § 12101 et seq. (ADA)], and retaliation in violation of the ADA.” Eccleston v. Waterbury, Docket No. 3:19-cv-1614 (SRU), 2021 WL 1090754, *3 (D. Conn. March 22, 2021). The District Court granted the defendant and O’Leary’s motion to dismiss with respect to the ADA claims. Id., *10. The District Court also declined to exercise supplemental jurisdiction over the state court claims and “dismissed [those claims] without prejudice to refiling in state court.” Id., *11. 8 With respect to the defamation claim, the plaintiff further alleged in the complaint that two other agents of the defendant—namely, Administrative Officer Adam Rinko, who wrote a 2018 investigation report regarding the plaintiff’s positive marijuana test, and Morgan— made defamatory statements concerning the plaintiff in regard to the plaintiff’s positive test for marijuana and subsequent discharge. At trial, however, the plaintiff withdrew the allegations with respect to the statements made by Rinko and Morgan, leaving only Martin’s state- ments as the basis for the plaintiff’s defamation claim. In its answer, the defendant asserted eight special defenses. The defendant asserted two special defenses as to the first count, namely, that the plaintiff’s claim was barred by the doctrines of res judicata and collateral estoppel insofar as it previously had been adjudicated before the State Board of Mediation and Arbitration. The defendant also asserted three special defenses as to the plaintiff’s defamation claim, namely, that the statements were true or matters of opinion, that the statements were not made with malice, and that the claim was barred insofar as the plaintiff was a public official at the time that the statements were made. Finally, the defendant also asserted three special  Eccleston v. Waterbury cross-examination of Martin, also introduced two exhib- its, namely, the last chance agreement and a laboratory report indicating that the plaintiff had tested positive for marijuana. After the plaintiff rested his case-in-chief, the defen- dant’s counsel orally moved to dismiss both counts of the plaintiff’s complaint for failure to make out a prima facie case pursuant to Practice Book § 15-8. The court reserved judgment on the defendant’s motion and afforded the defendant an opportunity to present evidence in its defense, which the defendant declined. On June 11, 2025, after both parties filed memoranda of law in support of their respective positions, the court issued a memorandum of decision in which it granted the defendant’s motion to dismiss for failure to make out a prima facie case, reasoning that “[t]he plaintiff . . . did not present evidence to establish a prima facie case for either of the counts in his complaint.” This appeal followed. We note that the plaintiff filed this appeal and his appellate briefs as a self-represented party. On November 10, 2025, Attorney Norman A. Pattis filed an appearance in addition to the plaintiff and thereafter represented the plaintiff at oral argument before this court. Additional facts and procedural history will be set forth as necessary. Practice Book § 15-8 provides in relevant part that, “[i]f, on the trial of any issue of fact in a civil matter tried to the court, the plaintiff has produced evidence and rested, a defendant may move for judgment of dismissal, and the judicial authority may grant such motion if the plaintiff has failed to make out a prima facie case. . . .” This court has explained that “[t]he standard for deter- mining whether the plaintiff has made out a prima facie case, under Practice Book § 15-8, is whether the plaintiff put forth sufficient evidence that, if believed, would establish a prima facie case, not whether the trier of fact defenses as to both counts, namely, governmental immunity, qualified immunity, and failure to mitigate damages.  Eccleston v. Waterbury believes it. . . . For the court to grant the motion [for a judgment of dismissal pursuant to . . . § 15-8], it must be of the opinion that the plaintiff has failed to make out a prima facie case. In testing the sufficiency of the evidence, the court compares the evidence with the allega- tions of the complaint. . . . In order to establish a prima facie case, the proponent must submit evidence which, if credited, is sufficient to establish the fact or facts which it is adduced to prove. . . . [T]he evidence offered by the plaintiff is to be taken as true and interpreted in the light most favorable to [the plaintiff], and every reasonable inference is to be drawn in [the plaintiff’s] favor. . . . Whether the plaintiff has established a prima facie case is a question of law, over which our review is plenary.” (Emphasis omitted; internal quotation marks omitted.) J. R. v. N. K., 232 Conn. App. 434, 440, 337 A.3d 14, cert. denied, 353 Conn. 902, 341 A.3d 958 (2025). The plaintiff’s evidence must meet a “relatively low standard” in order to withstand the defendant’s § 15-8 motion. (Internal quotation marks omitted.) Moss v. Foster, 96 Conn. App. 369, 378, 900 A.2d 548 (2006). Having set forth our standard of review, we now turn to the issues raised on appeal. I The plaintiff first claims that the court improperly concluded that he had failed to make out a prima facie case of wrongful termination in violation of PUMA. Specifically, the plaintiff argues that the court “erred in failing to apply the controlling McDonnell Doug- las [Corp. v. Green, 411 U.S. 792, 802, 93 S. Ct. 1817, 36 L. Ed. 2d 668 (1978) (McDonnell Douglas)] burden shifting framework” to his claim.9 Because this claim is 9 “In order to establish a prima facie case of employment discrimina- tion based on an adverse employment action under the burden shifting analysis enumerated by the United States Supreme Court in McDonnell Douglas . . . and adopted by [our Supreme Court] in Ford v. Blue Cross & Blue Shield of Connecticut, Inc., 216 Conn. 40, 53–54, 578 A.2d 1054 (1990) . . . the complainant must prove that: (1) [he] [was] in the protected class; (2) [he] was qualified for the position; (3) [he] suffered an adverse employment action; and (4) . . . the adverse action occurred  Eccleston v. Waterbury inadequately briefed, and because the plaintiff has failed to address the dispositive bases for the court’s conclusion, specifically, its rationale for rejecting the application of McDonnell Douglas in a case for wrongful termination under PUMA, we conclude that his claim is inadequately briefed and, therefore, decline to review it. The following additional procedural history is relevant to our consideration of this claim. In the first count of the operative complaint, the plaintiff alleged that the defendant wrongfully had terminated his employment solely on the basis of his status as a qualified patient in violation of PUMA pursuant to § 21a-408p (b) (3). Specifically, the plaintiff alleged that “the [defendant] engaged in unlawful employment practices by enforc- ing a ‘last chance’ agreement that was a pretext for discrimination . . . .” The plaintiff further alleged that, “[b]y putting [the plaintiff] on administrative leave and then [having] been lawfully prescribed marijuana . . . the defendant implemented [its] policies without regard to the [Connecticut] statutes prohibiting adverse employ- ment action on the basis of having a marijuana card.” When the defendant moved for dismissal under Prac- tice Book § 15-8, it argued, inter alia, that the plaintiff had failed to introduce evidence of pretext, as required under the burden shifting framework that was estab- lished in McDonnell Douglas. The plaintiff, also relying on McDonnell Douglas, argued, inter alia, that he had made out a prima facie case of wrongful termination under PUMA. In concluding that the plaintiff had failed to establish a prima facie case under PUMA, the court first noted that it “disagree[d] that, for the purpose of deciding a motion to dismiss under Practice Book § 15-8 in a PUMA under circumstances giving rise to an inference of discrimination. . . . The employer may then rebut the prima facie case by stating a legitimate, nondiscriminatory justification for the employment decision in question. The employee then must demonstrate that the reason proffered by the employer is merely a pretext and that the decision actually was motivated by illegal discriminatory bias.” (Internal quotation marks omitted.) Long v. Putnam, 236 Conn. App. 290, 300–301, 347 A.3d 178 (2025).  Eccleston v. Waterbury case, the burden shifting test in McDonnell Douglas applies.” The court explained that “[t]he elements of a claim under our discrimination laws are materially dif- ferent than the elements of a PUMA claim,” and “[t]he elements of a claim under PUMA eliminate the possibility of burden shifting.” The court reasoned that, “[u]nlike an employment discrimination claim under General Statutes § 46a-60,10 the legislature has made it an element of the plaintiff’s case to prove that there is no nondiscrimina- tory explanation for the defendant’s decision.” (Footnote added.) The court explained: “In addition to requiring a plaintiff to prove that he was a qualifying patient and was discharged, PUMA requires a plaintiff to prove, as an element of his claim, that the sole reason for the plain- tiff’s discharge was because of his status as a qualifying patient. In other words, the plaintiff bears the burden of proving that the defendant has no other legitimate reason to terminate him aside from his status as a quali- fying patient. The cause of action under PUMA places the burden of persuasion and production on the plaintiff for each element of the plaintiff’s claim.” (Emphasis in original.) The court further reasoned: “The legislature could have, but did not, add qualifying patients to the protected classes in employment discrimination claims. Instead, they established a different cause of action containing different elements for a case under PUMA. Accordingly, absent any guidance from the legislature or a binding court decision, the court concludes that a prima facie case under PUMA requires the plaintiff to offer some evidence which, if credited, is sufficient to 10 General Statutes § 46a-60 (b) provides in relevant part: “It shall be a discriminatory practice in violation of this section . . . (1) [f]or an employer, by the employer or the employer’s agent, except in the case of a bona fide occupational qualification or need, to refuse to hire or employ or to bar or to discharge from employment any individual or to discriminate against any individual in compensation or in terms, conditions or privileges of employment because of the individual’s race, color, religious creed, age, sex, gender identity or expression, marital status, national origin, ancestry, present or past history of mental dis- ability, intellectual disability, learning disability, physical disability, including, but not limited to, blindness, status as a veteran, or status as a victim of domestic violence . . . .”  Eccleston v. Waterbury establish that the sole reason for his discharge was his status as a qualifying patient, and there was no other legitimate reason for his discharge, taking the plaintiff’s evidence as true and interpreting it in the best light for the plaintiff.” The court then considered whether the plaintiff had introduced sufficient evidence that, if believed, would satisfy a prima facie case of termination in violation of PUMA. The court concluded that the plaintiff “pre- sented no facts in support of the claim that the reasons listed for his 2018 termination were simply a pretext to terminate him in violation of PUMA. He provided no evidence to support the claim that the real motivation in this case to terminate him was because of his status as a qualifying patient under PUMA. He provided no direct or circumstantial evidence that would call into question the real motivation behind the reasons used by the [defendant] to terminate him. He produced no evidence that the defendant allowed other firefighters to remain on active duty while using marijuana or that the reasons listed for his termination were not legitimate, leaving only his status as a qualifying patient as a basis for termination.” The court thereafter “examine[d] the reasons provided by the defendant for termination to determine if the plaintiff ha[d] made his prima facie case.” The court first addressed the plaintiff’s alleged violation of the last chance agreement, concluding that the last chance agreement made clear that the plaintiff’s employment could be terminated for any use of a controlled substance, including marijuana, and provided no exception for medical marijuana. The court further concluded that, under the express terms of the last chance agreement, the plaintiff had waived his rights under PUMA. The court then examined the plaintiff’s alleged violation of the substance abuse testing policy of the collective bargaining agreement and his alleged “endanger[ment] of the health and well-being of others.” The court similarly concluded that, because the plaintiff failed to put on any evidence  Eccleston v. Waterbury that would demonstrate that the defendant’s reasons for terminating the plaintiff’s employment “[were] not worthy of belief, or more likely than not [they were] not the true reason for termination, the plaintiff ha[d] failed to show that he was terminated solely for his use of marijuana” and, therefore, could not make out a prima facie case under PUMA. The court declined to address the defendant’s other reasons for terminating the plaintiff’s employment, noting that it “found that the plaintiff [had] failed to make a prima facie case that the sole reason for his discharge was because of his status as a qualifying patient by examining three of the reasons listed, any one of which defeats the plaintiff’s case.” On appeal, the plaintiff contends that the court improp- erly concluded that he failed to make out a prima facie case of termination in violation of PUMA. Specifically, the plaintiff claims that the court improperly failed to apply the McDonnell Douglas burden shifting framework to his claims.11 In support of this claim, the plaintiff asserts that “[t]his framework has been expressly adopted by Connecticut courts . . . and applies with equal force to claims brought under [PUMA].” (Citation omitted.) The plaintiff continues, “[r]ather than adhering to this well established sequence, the trial court erroneously collapsed the framework by requiring the plaintiff to refute the defendant’s proffered justifications at the 11 In his statement of issues, the plaintiff also claims that the court “improperly placed the burden on [him] to disprove the [defendant’s] justifications at the prima facie stage.” The plaintiff, however, has not provided a meaningful analysis of this claim. Instead, the plaintiff only baldly asserts that, “[r]ather than adhering to . . . [the McDonnell Doug- las burden shifting framework], the trial court erroneously collapsed [that] framework by requiring the plaintiff to refute the defendant’s proffered justifications at the prima facie stage, effectively shifting the burden prematurely.” We therefore decline to address this claim as inadequately briefed. See, e.g., C. B. v. S. B., 211 Conn. App. 628, 630, 273 A.3d 271 (2022) (“Analysis, rather than mere abstract assertion, is required in order to avoid abandoning an issue by failure to brief the issue properly. . . . [When] a claim is asserted in the statement of issues but thereafter receives only cursory attention in the brief with- out substantive discussion or citation of authorities, it is deemed to be abandoned.” (Internal quotation marks omitted.)).  Eccleston v. Waterbury prima facie stage, effectively shifting the burden pre- maturely. This misapplication contradicts long-standing precedent that the plaintiff’s initial burden is not oner- ous.” (Internal quotation marks omitted.) Finally, the plaintiff asserts that “[c]ourts have explicitly applied the McDonnell Douglas framework to claims under PUMA, recognizing that qualified medical marijuana use constitutes a protected status. . . . By refusing to apply this framework, the trial court imposed an improperly heightened standard on the plaintiff and deprived him of a fair adjudication.” (Citation omitted.) Having thoroughly reviewed the record and the plain- tiff’s briefs, we conclude that this claim is inadequately briefed, and, therefore, we decline to address it. “We repeatedly have stated that [w]e are not required to review issues that have been improperly presented to this court through an inadequate brief. . . . Analysis, rather than mere abstract assertion, is required in order to avoid abandoning an issue by failure to brief the issue properly. . . . For a reviewing court to judiciously and efficiently . . . consider claims of error raised on appeal . . . the parties must clearly and fully set forth their arguments in their briefs.” (Internal quotation marks omitted.) Alterio v. Spak, 237 Conn. App. 84, 90, 349 A.3d 614 (2026). This court also has declined to address claims because they are inadequately briefed where the party “fail[s] to address the dispositive bases for the court’s conclusion . . . .” Sicignano v. Pearce, 228 Conn. App. 664, 692, 325 A.3d 1127 (2024), cert. denied, 351 Conn. 908, 330 A.3d 881 (2025). We recognize that the plaintiff was a self-represented litigant at the time that he drafted his appellate briefs. The appellate courts of this state “have emphasized that it is the established policy of the Connecticut courts to be solicitous of [self-represented] litigants and . . . to con- strue the rules of practice liberally in [their] favor . . . . The courts adhere to this rule to ensure that [self-rep- resented] litigants receive a full and fair opportunity to be heard, regardless of their lack of legal education and  Eccleston v. Waterbury experience . . . .” (Internal quotation marks omitted.) Idlibi v. Hartford Courant Co., 350 Conn. 557, 569–70, 325 A.3d 1048 (2024). Nevertheless, “[a]lthough we are solicitous of the rights of [self-represented] litigants . . . [s]uch a litigant is bound by the same rules . . . and proce- dure as those qualified to practice law.” (Internal quota- tion marks omitted.) Idlibi v. Connecticut State Dental Commission, 231 Conn. App. 171, 173 n.1, 333 A.3d 196 (2025). In the present case, to the extent that the plaintiff claims that, by failing to apply the McDonnell Doug- las burden shifting framework to his claims, the court applied an incorrect legal standard to his claim of wrong- ful termination of employment in violation of § 21a-408p (b) (3), that claim is inadequately briefed. The limited arguments asserted by the plaintiff in support of this claim are bereft of legal analysis and are either patently incorrect or conclusory. See, e.g., State v. Coltherst, 192 Conn. App. 738, 757, 218 A.3d 696 (2019) (“[i]t is not enough merely to mention a possible argument in the most skeletal way, leaving the court to do counsel’s work, create the ossature for the argument, and put flesh on its bones” (internal quotation marks omitted)), aff’d, 341 Conn. 97, 266 A.3d 838 (2021). First, the plaintiff argues that courts previously have applied the McDon- nell Douglas burden shifting framework. The plaintiff cites only to Noffsinger v. SSC Niantic Operating Co., LLC, 273 F. Supp. 3d 326 (D. Conn. 2017), in support of this proposition. Such reliance is misplaced in that the District Court in Noffsinger made no mention of McDon- nell Douglas in its assessment of the plaintiff’s claims and, therefore, did not apply the McDonnell Douglas burden shifting framework. See generally id. The plain- tiff also baldly asserts that the court imposed an improp- erly heightened burden on him, but he has cited no case law in support of that assertion and has not explained how that burden was improperly heightened, especially given the court’s conclusion that PUMA requires that he produce some evidence to demonstrate that his employ- ment was terminated solely on the basis of his status  Eccleston v. Waterbury as a qualifying patient. See, e.g., State ex rel. Dunn v. Burton, 229 Conn. App. 267, 304, 327 A.3d 982 (2024) (“[c]laims are also inadequately briefed when they . . . consist of conclusory assertions . . . with no mention of relevant authority and minimal or no citations from the record” (internal quotation marks omitted)). Similarly, although the plaintiff argues that courts must apply McDonnell Douglas in the absence of direct evidence, he has not explained how that legal principle applies to the facts of this case and has not addressed the court’s reasoning, which led it to a contrary conclusion in the context of PUMA. See, e.g., id. (“[t]he parties may not merely cite a legal principle without analyzing the rela- tionship between the facts of the case and the law cited” (internal quotation marks omitted)). Moreover, the plaintiff has not adequately addressed “the dispositive bases for the court’s conclusion”; Sicig- nano v. Pearce, supra, 228 Conn. App. 692; namely, that the plaintiff failed to make out a prima facie case that the sole reason for his discharge was his status as a qualifying patient under PUMA. Although the plaintiff argues that it was improper for the court to require him to present evidence that would refute the defendant’s proffered justifications for termination when his burden is “not onerous,” the plaintiff has not addressed or even men- tioned the court’s reasoning for declining to apply the McDonnell Douglas burden shifting framework to assess whether, for the purposes of deciding a motion to dismiss pursuant to Practice Book § 15-8, the plaintiff made out a prima facie case. The plaintiff has not addressed the court’s analysis of PUMA, or its conclusion, based on the text of PUMA, that “[t]he cause of action under PUMA places the burden of persuasion and production on the plaintiff for each element of the plaintiff’s claim,” including demonstrating that he was terminated solely on the basis of his status as a qualifying patient, thereby “eliminat[ing] the possibility of burden shifting.” By failing to even discuss the grounds on which the court based its decision not to apply the McDonnell Douglas burden shifting framework to his claims, the plaintiff has failed to address the dispositive bases for the court’s  Eccleston v. Waterbury conclusion. See Sicignano v. Pearce, supra, 228 Conn. App. 691–92. Accordingly, his brief is inadequate for this court to conduct any meaningful review of this claim.12 II The plaintiff next claims that the court improperly concluded that he failed to make out a prima facie case of defamation. The defendant contends that, because the plaintiff has failed to challenge the court’s conclusion that he failed to present evidence that would support certain elements of his prima facie case, we should affirm the court’s judgment. We agree with the defendant. The following additional facts, taking the plaintiff’s evidence as true and viewing it in the light most favorable to him, and procedural history are relevant to the resolu- tion of this claim. In the second count of his operative complaint, the plaintiff alleged “defamation of charac- ter” on the basis of certain statements allegedly made by Martin “to the . . . newspaper that [the plaintiff’s] use of medical marijuana endangered others and constituted criminal conduct,” as well as Martin’s statement in the termination letter “that [the plaintiff] endangered the health and well-being of others . . . which was courtesy copied to others, including the defendant’s city attorney . . . .” In support of his claim, the plaintiff introduced into evidence the article, which discusses two employees, one of whom was the plaintiff, whose employment with the fire department had been terminated on the basis of results from the fire department’s random drug test- ing program. The article’s author attributes several 12 As noted herein, under McDonnell Douglas, a plaintiff bears the initial burden to demonstrate a prima facie case of discrimination. In the present case, the court concluded that, in order to establish a prima facie case under PUMA, the plaintiff was required to prove that his employment was terminated solely on the basis of his status as a qualifying patient. The court found that he failed to do so. We there- fore agree with the acknowledgement by the plaintiff’s counsel at oral argument before this court that the court’s rejection of the application of McDonnell Douglas to a claim of wrongful termination under PUMA did not affect the outcome of this case.  Eccleston v. Waterbury statements to Martin.13 The article also includes a refer- ence to a disciplinary hearing in which the plaintiff was found to have “engaged in the use of marijuana to the endangerment of the health and well-being of others . . . .” The article’s author, however, does not attribute that reference to Martin. In its brief in support of its Practice Book § 15-8 motion, the defendant argued, inter alia, that “the plaintiff ha[d] failed to present a prima facie case that any statements made by Martin in the . . . [article] were defamatory, that he suffered any damage to his professional and/or personal reputation in the community, that he sustained any personal and/or emotional injuries and that he sus- tained a loss of earnings.” The defendant also contended that, insofar as the plaintiff claimed that the termination letter was released to the media by Martin, the plaintiff “clearly presented no evidence of Martin’s involvement [in that release].”14 The plaintiff argued, inter alia, that 13 The court identified the following statements as attributable to Martin: “ ‘Our [fire] department is made up of very conscientious profes- sionals . . . .This is not indicative of the overall population of our [fire] department. These are two isolated incidents and people shouldn’t think it’s a reflection on the whole job.’ The program of random screening began after a change in the union contract, Martin said. Previously, the [fire] department could call for a test if concerns were raised about a particular individual, he said. Martin said the [fire] department dealt with the positive tests swiftly. ‘We take the safety of our members and the public very seriously,’ Martin said. ‘These are things we don’t tolerate.’ ” 14 The defendant also argued that “any statements made by Martin are protected by a qualified privilege,” and that, insofar as malice might “defeat” that qualified privilege, “[t]he plaintiff failed to introduce any evidence of malice by Martin.” The defendant further contended that “[a]nother privilege that would apply in this case is the privilege of fair comment” and that the plaintiff had failed to present evidence that he made efforts to mitigate damages. The trial court never made any conclusions concerning the defendant’s assertion of those privileges, or whether the plaintiff had produced sufficient evidence of malice. In this appeal, the defendant has not renewed its claim that it would be entitled to either privilege for these statements. The defendant also argued that the plaintiff had failed to present evidence of damages. The trial court did not address the issue of the sufficiency of the plaintiff’s evidence as to damages, and the defendant has not renewed this argument on appeal.  Eccleston v. Waterbury “[t]he defendant does not dispute that the statement is per se defamatory, nor does the defendant dispute [that] the statement was published.” The trial court concluded that the plaintiff had failed to produce sufficient evidence to establish a prima facie case of defamation. The court first explained: “To estab- lish a prima facie case, the plaintiff was required to submit some evidence to support each of the e