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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.

Experiencing stress and anxiety regarding the impending change, Hanke applied for and received short-term disability benefits administered by a third-party vendor. After exhausting his short-term disability leave, Hanke successfully applied for long-term disability benefits. Under Electric Boat’s policy, approval for long‑term disability resulted in administrative termination. Despite being told by Electric Boat to do so, at no point before his termination did Hanke request a leave of absence or provide any projected return‑to‑work date. Hanke was medically cleared to return to work after his termination and subsequently brought claims under the Connecticut Fair Employment Practices Act (CFEPA) for disability discrimination, failure to accommodate, and retaliation.

The trial court granted Electric Boat’s motion for summary judgment as to all counts and Hanke appealed.

Holding

On appeal, Hanke argued that the trial court erred in granting summary judgment on his disability discrimination claim because a genuine issue of material fact existed with respect to whether he was qualified to perform the essential functions of his job at the time of his termination, with the reasonable accommodation of a leave of absence. The Connecticut Appellate Court disagreed, finding that attendance at work is a necessary job function and Hanke did not claim he was able to perform the essential functions of his job without the accommodation of a leave of absence. Because the only accommodation identified by Hanke—a leave of absence—was never requested and was effectively indefinite given the absence of any return‑to‑work estimate, no reasonable accommodation existed that would have enabled Hanke to work at the relevant time.

Relying on the same facts that resolved the discrimination claim, the Court also affirmed summary judgment on Hanke’s failure to accommodate claim, finding there was no request for a reasonable accommodation because Hanke never sought a leave of absence. And because Hanke never requested a reasonable accommodation in the form of a leave of absence, the Court further determined he had not engaged in a protected activity, thereby dooming his retaliation claim.

Implications for Connecticut Employers

The Hanke decision affirms that disability benefits are not a substitute for leave of absence requests. As the Court articulated, while a finite leave of absence is generally a reasonable accommodation, an employer is not required to hold a position open indefinitely. Furthermore, the decision underscores the importance of engaging employees requesting a medical leave of absence in an interactive process by inviting an approximate return date from a health care provider.