CFEPA Update: Disability Benefits Don’t Replace An Employee’s Accommodation Request

On April 7, 2026, the Connecticut Appellate Court decided Hanke v. Electric Boat Corp., a disability discrimination case highlighting the distinction between requests for medical leaves of absence and applications for disability benefits in the CFEPA context.

Background

The plaintiff, Stuart Hanke, was an engineering supervisor at Electric Boat. In May 2019, Hanke arrived to a meeting late and was subsequently observed dozing off during the meeting. As a result, human resources issued Hanke a letter of reprimand. Four months later, in September 2019, a significant number of employees under Hanke’s supervision resigned from Electric Boat. Hanke’s supervisor determined that the high attrition rate was the result of Hanke’s performance. Hanke was informed he would be asked to accept a demotion to an engineering specialist role while maintaining the same salary.