New Decision Reaffirms Roadmap for Employers on the Interactive Process

Key Takeaways

• Interactive process requires employee request; silence defeats accommodation claim
• Disability benefit applications do not equal leave of absence requests
• Indefinite leave without return date is not a reasonable accommodation
• Documented communications can secure summary judgment for employers
• Employers may terminate long‑term disability employees per policy after proper notice

Pulse Analysis

Connecticut’s disability‑accommodation jurisprudence has evolved dramatically since the 2008 Curry decision, which first imposed a state‑wide interactive‑process duty. Hanke v. Electric Boat Corp., released in April 2026, adds a decisive layer by confirming that merely receiving short‑term disability benefits does not satisfy an employee’s obligation to request a formal leave. The appellate court’s reliance on the McDonnell Douglas framework underscores that a prima facie case collapses when the worker cannot demonstrate eligibility to perform essential job functions, even with a hypothetical accommodation.

For human‑resources leaders, the ruling translates into actionable best practices. Companies must maintain separate, clearly communicated channels for disability benefits and leave‑of‑absence requests, ensuring employees understand that the two are not interchangeable. Proactive outreach—emails, phone calls, and documented check‑ins—creates a paper trail that can be decisive in summary‑judgment motions. Moreover, policies that automatically terminate long‑term disability employees, when applied consistently and transparently, are now reinforced by judicial precedent, reducing exposure to retaliation claims.

The broader impact extends beyond Connecticut. As courts across the nation grapple with the balance between employee protections and operational realities, Hanke offers a template for limiting indefinite leave as a reasonable accommodation. Employers should audit their accommodation procedures, train managers on the necessity of explicit employee requests, and integrate robust documentation protocols. By doing so, they not only mitigate litigation risk but also align with evolving legal standards that demand clear, mutual communication in the accommodation process.