No, your business does not always have to say yes to an employee who wants to work from home or remotely. If an essential function of the position is attendance in person, at a physical location, Connecticut employers can require that even if employee has a disability.

A recent case from the United States Court of Appeals for the Fourth Circuit offers helpful guidance for employers navigating disability accommodation and hybrid-work issues—topics that continue to generate significant employment litigation in Connecticut and throughout the Northeast.

Although the case arose outside Connecticut, the court’s reasoning closely mirrors how federal courts applying the ADA—including those in Connecticut—analyze accommodation, attendance, and retaliation claims.

The Case in Brief

In Haggins v. Wilson Air Center, LLC, the employee was diagnosed with breast cancer during the COVID-19 pandemic and permitted to work fully remotely while business operations were slowed. As business rebounded, the employer determined that several essential job functions—including accounts payable processing, handling mailed invoices, issuing checks, and maintaining physical files—required at least part-time, in-office work.

The employer proposed a flexible hybrid schedule, offered to work around medical appointments, and implemented health precautions. Despite agreeing to return, the employee largely failed to appear in person and frequently did not communicate her absences. After repeated no-shows and weeks of missed work, the employer terminated her employment for job abandonment.

The employee sued under the ADA for discrimination, failure to accommodate, and retaliation. The district court granted summary judgment for the employer, and the Fourth Circuit affirmed in a unanimous, published opinion.

Why This Matters for Connecticut Employers

First, Connecticut’s appellate court issued a decision in 2025 that is employer friendly just like the Fourth Circuit’s decision above. In that case, called Castelino v. Whitman, Breed, Abbott & Morgan, the appellate court ruled that presence in the office can be an essential function and thus remote work as an accommodation was not reasonable. An older case, Barbabosa v. Board of Education of Manchester, also held that attendance in person can be an essential function of a position. Another case called Tudor v. Whitehall Cent. Sch. Dist., may weaken the significant of those two cases.  In Tudor, the Second Circuit Court of Appeals (which is on the same level as the Fourth Circuit but specifically applies to Connecticut) found that an employee no longer needs to prove that a requested accommodation was necessary for the employee to perform their essential job duties. The question is only whether the accommodation is reasonable, meaning can the employer provide it without undue hardship.

Connecticut employers who have at least 15 employee are subject to both federal ADA standards and Connecticut’s Fair Employment Practices Act (CFEPA). While CFEPA can be broader in some respects, courts regularly look to federal ADA case law for guidance—particularly on issues like essential functions, attendance, and the interactive process.

This decision reinforces several principles that are directly relevant to employers operating in Connecticut. And smaller employers in particular since they are more likely to be flexible when it comes to remote work.

In Person Attendance Can Be an Essential Job Function

The court reaffirmed that regular and reliable attendance is often essential, particularly where job duties require physical presence. Employers are entitled to deference in defining essential functions, so long as those functions are legitimate and well-documented.

Remote or hybrid work arrangements adopted during COVID do not automatically become permanent accommodations—especially when business needs change.

The Interactive Process Is a Two-Way Street

Connecticut employers are required to engage in a good-faith interactive process, but the law does not require employers to accept every accommodation request or tolerate ongoing non-communication.

Here, the employer repeatedly attempted to coordinate schedules and accommodate medical needs. The employee’s failure to follow through—or even communicate—ultimately undermined her claims. Courts will not penalize employers where accommodation efforts fail due to an employee’s lack of cooperation.

Employers Are Not Required to Eliminate Essential Functions

The court emphasized that employers are not obligated to restructure jobs, permanently reassign core duties, or distribute essential functions among other employees as an accommodation. This is particularly important for Connecticut businesses operating with lean teams, where redistributing work is often impractical.

Retaliation Claims Require More Than Timing

The employee also alleged retaliation after complaining to HR. The court rejected that claim, finding no causal connection where the employer continued accommodation efforts and terminated employment only after sustained attendance and communication failures.

For Connecticut employers, this reinforces the importance of documenting legitimate, non-retaliatory reasons for employment decisions.

Law Junkie Practical Guidance for Connecticut Businesses

To reduce exposure to ADA and CFEPA claims, Connecticut employers should consider:

• Regularly reviewing job descriptions to ensure essential functions are accurately stated
• Documenting accommodation discussions, attendance issues, and communications in real time
• Training managers on how and when to escalate accommodation issues to HR or counsel
• Reassessing accommodations when business conditions change
• Addressing attendance and communication problems consistently and promptly

Bottom Line

This decision confirms that courts will support employers who act reasonably, compassionately, and consistently—while still enforcing legitimate business requirements. Connecticut employers are not required to choose between operational needs and compliance with disability laws.

When accommodation issues become complex or contentious, early legal guidance can help employers strike the right balance and avoid costly litigation.