Butler v. Hartford Technical Institute, Inc
In Butler v. Hartford Technical Institute, Inc., 243 Conn. 454, 704 A.2d 222 (1997) the Court established the test to determine who is an employer for purposes of the statute.
"The term employer as used in 31-72 encompasses an individual who possesses the ultimate authority and control within a corporate employer to set the hours of employment and pay wages and therefore is the specific or exclusive cause of improperly failing to do so." Id., 462.
The Court concluded "that an individual personally can be liable as an employer pursuant to 31-72, notwithstanding the fact that a corporation is also an employer of the claimant, if the individual is the ultimate responsible authority to set the hours of employment and to pay wages and is the specific cause of the wage violation." Id., 463-64.